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Home My WebLink About99-04457 r ® . DRANOFF-PERLSTEIN ASSOCIATES BY: ROBERT J. FOSTER, ESQUIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION NO.: 61912 1604 SPRUCE STREET PHILADELPHIA, PA 19102 (215) 732-3333 LAB CORPORATION OF AMERICA, formerly known as NATIONAL HEALTH LABORATORIES, INC. also formerly known as ROCHE BIOMEDICAL LABORATORIES, INC. Suite 405, Quality Place 300 East Main Street Lexington, Kentucky 40507 Plaintiff, V GADANI ASSOCIATES 30 East Shady Lane Enola, Pennsylvania 17025 Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 94- (I?/Sr? ?V?l??l2Yl N O T I C E 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 other rights important to you. II 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. Lawyer Reference Service Two Liberty Avenue Carlisle, PA 17013 717-249-3166 DRANOFF-PERLSTEIN ASSOCIATES ARBITRATION CASE ASSESSMENT OF DAMAGES HEARING NOT REQUIRED DRANOFF-PERLSTEIN ASSOCIATES BV: ROBERT J. FOSTER, EsauIRE ATTORNEY FOR PLAINTIFF IDENTIFICATION No.: 61912 1604 SPRUCE STREET PHILADELPHIA, PA 19102 12151732-3333 LAB CORPORATION OF AMERICA, formerly known as NATIONAL HEALTH LABORATORIES, INC. also formerly known as ROCHE BIOMEDICAL LABORATORIES, INC. Suite 405, Quality Place 300 East Main Street Lexington, Kentucky 40507 Plaintiff, V. GADANI ASSOCIATES 30 East Shady Lane Enola, Pennsylvania 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. Plaintiff, National Health Laboratories, Inc., by and through its attorneys, hereby demand judgment against the defendant, in a sum not in excess of $50,000.00, plus costs and avers as follows: DRANOFF PE RLSTEIN ASSOCIATES 1 . Plaintiff, National Health Laboratories, Inc., is a corporation licensed to practice business in the Commonwealth of Pennsylvania. 2. Defendant, Gadani Associates, is a healthcare provider, licensed to practice in the Commonwealth of Pennsylvania, whose principal place of business as above captioned. 3. Plaintiff is in the business of providing medical laboratory specimen testing services for which plaintiff receives compensation per monthly compensation upon a set fee schedule. 4. From April 1995 to April 1998, defendant requested that plaintiff perform laboratory work in support of its medical care practice. Defendant agreed to pay plaintiff its standard fee for the performance of these services. 5. The plaintiff performed the work as requested by defendant. 6. Pursuant to the agreement between the parties, the plaintiff submitted monthly statements of accounts to defendant for its customary charges for these services. 7. The services rendered by plaintiff to defendant were at all times proper, satisfactory, and consistent with and in performance of the agreement between the parties. 8. To date, there exists and remains an outstanding balance on the account stated of $4,552.58. A true and correct copy of the outstanding invoice is attached hereto as Exhibit "A". 3 OPl1 NOI f-Pk. PLSTC IN A550C IA 1'CS 9. Despite repeated demands, defendant has failed and refused to pay the outstanding balance of $4,552.58 to plaintiff. WHEREFORE, plaintiff requests judgment against defendant in the amount of $4,552.58, together with costs and interest from the date of demand, and such other relief as is just and equitable. DRANOFF-PERLSTEIN ASSOCIATES BY: ' ROBERT J. FOSTER, ESQUIRE Attorney for Plaintiff 4 ORANOFF-RERLSTEIN ASSOCIATES The undersigned verifies that the facts set forth herein are true and correct. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsifications to authorities. Date: 7- 7- ORANOFF PERLSTEIN ASSOCIATES Exhibit A r wlty Isldwlw s 04/16/1998 Perkins Law Group Page 1 DEBTOR LISTING vswv ........................................... a.aa.===acs=m=...=. . .. c...=.. a........ CREDITOR....: LCA-007 - LCA - B. Woollard Phone.....: (800) 222.7566 ( ) -5512 Fax: (910) 222.9529 .......................................................................................... DEBTOR-1....: 971278 - Gadani Associates LINK..: AKA or T/A..: P. Gadani, M.D./ M. Gadani, X.D. Address...: 30 East Shady Lane City/St/Zp: Eno Is PA 17025 County: Phom..... : (717) 732.4911 (717) 752.6092 Fax SSN...: Salutation: Mrs. Gadani D.O.S.: DEBTOR-2....: AKA or T/A..: Address...: City/St/Zp: County: Phone.....: SSN...: Salutation: D.O.B.: MEN01....... : MEN02....... : MEN03....... : GARNISHEE...: Carn. Int. Dt.: Address...: City/St/Zp: County: Attention.: Wages.....: 0.00 Years Eapl.: 0 VEHICLES....: PROPERTY: BANK ACCOUNT: OTHER...: .................... CLAIM: 971278.00 REF. ACCT. #: 50443.10 TYPF: Status<PR:1>: 027 Need to Transfer (04/08/1998) PRINCIPAL INTEREST FEES COSTS TOTAL Dim.......: 2252.53 0.00 0.00 0.00 2252.53 Charges....: 0.00 0.00 0.00 0.00 0.00 Payments...: 0.00 0.00 0.00 0.00 0.00 Adjustments: 2300.05 0.00 0.00 0.00 ........... . 2300.05 . .. Balance....: .......... 4552.58 .......... . 0.00 ...... . 0.00 0.00 ...... . 4552.58 New Interest.....: 0.00 Bel w/New Int....: 4552.58 Last Pymt..: 50.00 Attorney.....: Resp: FILL Orig: SLP Pre-Jmt Int..: 0.00% Open Date....: 08/13/1997 Post-Jmt Int.: 0.00% Open Balance.: 2252.53 Begin Int Dt.: 08/13/1997 For..........: Interest Date: 08/13/1997 Contract date: Filing Date..: / / Payment Plan.: 0.00 Service Date.: / / Tot Collected: 0.00 Judgment Date: / / Coll Fee.....: 25.0% Contin S. Fee: Judgment Amt.: 0.00 Court File #.: Close Date...: / / Court........: 04/16/1998 Page 2 DEBTOR LISTING .................... .................... HISTORY: 971278.00 - ................................................... LCA - B. Woollard v. Gadani Associates ........ 08/13/1997 I DPW 2252.53 Initial balance due MKW 08/13/1997 INIT STAY: 010-File Opened - No Demand MKW 08/13/1997 F First Demand letter sent MKW 08/13/1997 STAT CHNG: 011-First Demand Letter Sent MKW 08/13/1997 FW 08/25/1997 DEMANDI/OPER 1897 MKW 09/25/1997 T/C spoke with Alice, she said that Ms. MKW 0912511997 Gadani is out at the moment. She handles MKW 09/25/1997 A/P. Will have her call. MKW 09/25/1997 STAT CHNG: 012-Awaiting Debtor Response MKW 09/30/1997 T/C spoke to Mrs. Gadani, said she MKW 09/30/1997 thinks they received a credit balance MKW 09/30/1997 invoice. Will check on this and call back. MKW 09/30/1997 Confirmed her mailing address, fax number MKW 09/30/1997 now listed. MKW 10/06/1997 T/C s/w Alice, said Mrs. Gandani is out MKW 10/06/1997 of the office. Left message for her. MKW 10/15/1997 P CP 2300.05 +acct. 37685593 7214 KWI 10/15/1997 F Additonal charges added to original balance KWI 10/15/1997 FW 10/27/1997 AODCHRGS/OPER 1897 KWI 10/21/1997 T/C s/w Alice, she said Mrs. Gadani was MKW 10/21/1997 tied up and couldn't came to the phone. Left MKW 10/21/1997 detailed message. Will generate second MKW 10/21/1997 demand. MKW 10/22/1997 F Second Demand letter sent MKW 10/22/1997 STAT CHNG: 021-2nd demand sent/await respons MKW 10/22/1997 FW 11/03/1997 DEMAND2A/OPER 1897 MKW 11/25/1997 TC to Mrs. Gadani, s/with recp. said she RLL 11/25/1997 was on another line, left message important Rll 11/25/1997 that she calls me back ref. LCA past due RLL 11/25/1997 account. RLL 02/16/1998 Never returned my call, I will send FILL 02/16/1998 final demand letter on 2/17/98. RLL 02/17/1998 F Final Demand sent RLL 02/17/1998 STAY CHNG: 031-final demand sent/await rspns JILL 02/17/1998 FW 02/2711998 FINAL/OPER 1897 RLL 02/23/1998 Received note from Gadani, said account RLL 02/23/1998 was resolved a long time ago, he had sent an RLL 02/23/1998 invoice from same other lab showing write RLL 02/23/1998 off 0 balance. 1 faxed him letter stating to JILL 02/23/1998 look at invoice and the account numbers RLL 02/23/1998 totally different from LCA. RLL 02/23/1998 I told him the letter we sent to him is RLL 02/23/1998 still standing. We must receive a call or RLL 02/23/1998 Payment by S:OOpm tomorrow or we will RLL 02/23/1998 transfer to local counset. RLL 02/25/1998 No response from Dr. Gadani, 1 will RLL 02/25/1998 give to Brooke for transfer to local today. RLL 04/16/1998 Page 3 DEBTOR LISTING ......................................................... HISTORY: 971278.00 - LCA - B. Woodard V. Gadant Associates LCONT.) 04/08/1998 STAT CHNG: 027-Need to Transfer FILL Y L Lf: , Il.l ? Lt U ?- J L? V CJU V V SHERIFF'S RETURN - REGULAR CASE NO: 1999-04457 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAB CORPORATION OF AMERICA VS. GADANI ASSOCIATES CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT was served upon GADANI ASSOCIATES the defendant, at 14:25 HOURS, on the 29th day of July 1999 at 30 EAST SHADY LANE ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to LINDA CHESKEY (MEDICAL ASST) a true and attested copy of the NOTICE AND COMPLAINT and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 So answer 9.92 .00 8.00 omas ine, eri 07RA OF-9gRLSTEIN ASSOCIATES by Sworn and subscribed to before me this 36 r{, day of 19A, D. ---?,, ,•,, n nonot u q4tW PRAVIN GADANI, M.D. FAMILY /INTERNAL MEDICINE TESTS FOR HEART & BLOOD VESSELS OUTPATIENT CLEARANCE FOR SURGERY 30 E. SHADY LANE LOWER BOWEL (COLON) EXAM ENOLA, PA 17025 LAB 8 MINOR SURGERIES (717) 732.4911 CANCER SCREENINGS FAX ULTRASOUNDS (717) 7326092 24 HOUR COVERAGE August 18, 1999 Court of Common Pleas Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 RE: Case 099-4457 Honorable Judge: I am an internist practicing since 1980 in Pennsylvania. I would like to defend this suit against "432dani Associates", a corporation established in Pennsylvania. I was out of town when my office accepted this claim. Thank you. Sincerely, Pravi? ani J April 5, 2000 LS E:bf lse\lab-ent.wd 26 ry S.EiisStreetsquire Attorney for Plaintiff . 16t4 Phil5adelphia, PA 19102 215 732 5600 Lab Corpporation pf America, fka National: Court of Common Pleas Hgalth,Laboratories,Inc. afka Roche Cumberland County Biomedical Laboratories, inc. 1999 04457 P V. Gadani Associates Entry of Appearance To the Prothonotary: Enter the Appearance of Larry S. Eisman, Esquire for the Plaintiff herein. V'V Larry S. Eisman,,Esquire Morney for Plaintiff Withdrawal of Appearance Withdraw the Appearance of Dranoff-Perlstein Associates for the plaintiff herein. Dranoff-Perlstein Associates By: Y wL?? o Iteven M. Dranoff, Esquire lj_yc5 ?, ??-. -- ;; ,. Rule of Civil Procedure No. 236 - Revised In The Court of Common Pleas of Cumberland County, Pennsylvania TO: Gadani Associates 30 East Shady Lane Enola, PA 17025 Lab Corporation of Americo, fka Court of Common Pleas National Health Laboratories inc. Cumberland County afka Roche Biomedical Laboratories, Inc. 1999 04457 P V. Gadani Associates Notice is given that a judgment in the above captioned matter has been entered against you on 12L., Prothonotary Deputy If you have any questions concerning the above please contact: Larry S. Eisman, Esquire 262 South 16th Street Philadelphia, PA 19102 215 732 5600 lse\def-j LSE: bf lse\def2l 00 Larry S. Eisman, Esquire ID #19738 262 S. 16th Street Philadelghia, PA 19102 215 732 5600 Attorney for Plaintiff Lab Corporation of America, fka Court of Common Pleas National Health Laboratories inc. Cumberland County afka Roche Biomedical Laboratories, Inc. Suite 405, Quality Place 1999 04457 P 300 E. Main Street Lexington, KY 40507 V. Gadani Associates 30 Shady Lane Enola, PA 17025 Praecive for Judgment To The Prothonotary: Enter judgment in favor of Plaintiff and against Gadani Associates for want of an answer and assess damages as follows: Debt Credits Total Judgment Debt $4,552.58 0.00 $4,552.58 I certify that the foregoing assessment of dame es is for specified amounts to be due in the Complaint and is calculable as sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed to the party agqainst whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the dae of the filing of this Praecippe. A copy of the notice pursuant to Pa. R.C.P. 237.1 attached. I certify that the addresses set forth above are correc L Larry S. Eisman IDtorng for Plaintiff AND NOW, this Z q-k day of La?Z , 2000, Judgment is entered in favor of Lab Corporation of merica, inc and against Gadani Associates by default for want of an answer and damages are assessed at the sum of $4,552.58 as per the bove certific on. Prothonotary lse:bf May 8, 2900 LarZr19738Eisman, Esquire Attorney for Plaintiff Philadelghia, PA e19102 215 732 5600 Lab Corporation of America, fka Court of Common Pleas National Health L@boratories Inc. Cumberland County afkka Roche Biomedical Laboratories, Suite 405, Quality Place 1999 04457 P 300 E. Main Street Lexington, KY 40507 V. Gadani Associates 30 Shady L17025 Enolala, FA Certification The undersigned certifies that the above defendant was notified in writing by letter mailed on April 25, 2000 of plaintiff's intention to file a Praecipe for Entry of Default Judgment ten (10) days thereafter. A copy of the said letter is attached. Y -? L? Larry S. Eisman Attorney for Plaintiff LARRY S. EISMAN ATTORNEY AT LAW (215)732.5600 FAX (215) 732-7758 262 SOUTH 16TH STREET PHILADELPHIA, PA 19102 April 25, 2000 Gadani Associates 30 East Shady Lane Enola, PA 17025 Lab Corporation of America, fka court of Common Pleas of National Aea?th Laboratories inc. Cumberland County afka Roche Biomedical Laboratories, e Inc. 1999 04457 P V. Gadani Associates IMPORTANT NOTICE Cumberland County Bar Association 2 Liberty Avenue Carlisle PA 17103 717 249 5166 . 9?=? Larry S. Eisman, Attorney for Plaintiff lse\10-day GJi t [iJ' LI U O U 1 December 1, 2000 lse\sat.j Larry S. Eisman, Esquire I.D. # 19738 Attorney for Plaintiff 262 S. 16th Street, Suite 200 Philadelphia, PA 19102 (215) 732-5600 Lab Corporation of America, Inc. Court of Common Pleas fka National Health Laboratories, Cumberland County Ind., afka Roche Biomedical Laboratories, Inc. 1999 04457 P V. Gadani Associates Praecive to Satisfy Judgment To the Prothonotary: Mark this judgment satisfied upon payment of your costs only. Larry S. Eisman Attorney for Plaintiff cir L 21 Q `Z G O ? j U