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HomeMy WebLinkAbout01-6169MARLENE M. PALMER, Plaintiff SYNERTECH HEALTH SYSTEM SOLUTIONS, 1NC. a/k/a SYNERTECH HEALTH SYTEMS, LLC, and HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY a/k/a HARTFORD LIFE INSURANCE COM~PANY, Defendants : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2001- 6l~q CIVIL TERM CIVIL ACTION - LAW PRAECIPE FOR ISSUANCE OF A WR/T 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 Respectf~lly~bm~ /Mark D. Schwar~'~,~quire 60 West Pomfret Street, Carlisle, PA 17013 (717) 249-2353 - Supreme Court I.D. No: 70216 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 Date: ~ c~ (_0; 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. _ _ pRO,i~NOT(~4/' ,2001 By: .~[~ !E~,F_~U~ ~~ MARLENE M. PALMER, Plaintiff 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. 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 Dated: November 7, 2001 CERTIFICATE OF SERVICE I hereby certify that on this 7th day of November, 2001, a tree 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 SHERIFF'S RETURN CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PALMER MARLENE M VS. SYNERTECH HEALTH SYSTEM SOLUTI CERTIFIED MAIL 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 and attested copy of the attached WRIT OF SUMMONS with receipt card was signed by BRENDAN STONE 10/31/2001 a true Together The returned on 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/~ ~' day of~,_,,~.~-~ A.D. t ; So an~s :/.~/~ ~~ t~..' Thomas Kline Sheriff of Cumberland County on 12/06/2001 SHERIFF'S RETURN - U.S. CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PALMER MARLENE M VS. SYNERTECH HEALTH SYSTEM SOLUTI CERTIFIED MAIL R. Thomas Kline , Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,HARTFORD LIFE 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 and attested copy of the attached WRIT OF SUMMONS with receipt card was signed by BRENDAN STONE 10/31/2001 , a true Together The returned on 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 /~ day of ~_,~ ~of A.D. T ~rothonot ary So an~s: j ~'~ ~.~/ tR. Thomas Kline Sheriff of Cumberland County on 12/06/2001 SHERIFF'S RETURN - CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALMER MARLENE M VS SYNERTECH HEALTH SYSTEM SOLUTI OUT OF COUNTY R. Thomas Kline duly sworn according to and inquiry for the within named DEFENDANT , to wit: SYNERTECH HEALTH SYSTEM SOLUTIONS INC , Sheriff or Deputy Sheriff who being law, says, that he made a diligent search and in his bailiwick. County, He therefore Pennsylvania, but was unable to locate Them deputized the sheriff of DAUPHIN serve the within WRIT OF SUMMONS to On December 6th , 2001 attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 12/06/2001 , this office was in receipt of the IRWIN MCKNIGHT HUGHES Sworn and subscribed to before me this ./_~ day of ~ J~/ A.D. ! ! Prothonot'ar~ SHERIFF'S CASE NO: 2001-06169 P COMMONWEALTH OF PENNSYLVkNIA: COUNTY OF CUMBERLB-MD PALMER MARLENE M VS SYNERTECH HEALTH SYSTEM SOLUTI RETURN - 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: SYNERTECH HEALTH SYSTEMS LLC but was unable to locate Them in his bailiwick. deputized the sheriff of PHILADELPHIA County, serve the within WRIT OF SUMMONS He therefore Pennsylvania, to On Decembe~r 6th , 200__1 , this office was in receipt of the attached return from PHILADELPHIA . Sheriff's Costs: ~,~ms~// //// Docketing 6.00 ~--~ _ Out of County 9.00 /~~'~ .~/ Surcharge 10.00 ~.~T~.~as k~e ~" Dep Philadelphia 116.00 /gheJiff of Cumberland County 12/06/2001 IRWIN MCKI~IGHT HUGHES Sworn and subscribed to before me this /3 ~ day of ~/z6~-~ 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 County of Dauphin AND NOW:November 9, SUMMONS SYNERTECH HEALTH SYSTEMS SOLUTIONS INC to ED LOSCHER, VP OF CONTRACTS of the original SUMMONS to him/her the contents thereof at 2400 THEA DRIVE HARRISBURG, PA PALMER MARLENE M vs : SYNERTECH HEALTH SYSTEMS SOLUTIONS INC Sheriff's Return No. 3123-T - -2001 OTHER COUNTY NO. 01-6169 2001 at 9:00AMserved the within upon by personally handing 1 true attested copy(ies) and making known 17110-0000 Sworn and subscribed to efore me this 9TH day o~VEMiER, 2~00~! PROTHONOTARY So Answers, ~WDeputy Sheriff Sheriff's Costs: $29.25 PD 10/30/2001 RCPT NO 156023 TORO SERVE: In The Court of Common Pleas of Cumberland County, Pennsylvania Marlene M. Palmer VS. Synertech Health System Solutions, Inc. same N0. 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 Now~ within Affidavit of Service ., 20 , at o'clock M. served the upon by handing to a and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this __ day of ,20 Sheriff of COSTS SERVICE MILEAGE AFFIDAVIT County, PA In The Court of Common Pleas of Cumberland County, Pennsylvania Marlene M. Palmer VS. Synertech ,Healt~ System Solutions, Inc. SERVE: NO. 01 6169 civil Synertec~ Health Systems LLC Now, October 29 hereby deputize the Sheriff of deputation being made at the request and risk of the Plaintiff. ,20 01 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do Philadelphia County to execute this Writ, this PA Now~ within Affidavit of Service ,20 ,at o'clock M. served the upon by handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT SHERIFF'S RETURN-NOT FOUND VERSUS COMMON PLEAS NO. COUNTY COURT .0.5/ TERMS/ defendant, within the County of Philadelphia, State of Pennsylvania, as of / / So answers, By: ~ 12-225 (Rev. 12/87) the above named Deputy Sheriff · Comptete items 1, 2, and 3. Aiso complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the can3 to you. · Attach this card to the back of the rnailpiece, or on the f~ont if space parmifs. 1. Article ,~%~essod tO: H~ Life & Accident Inst~ ~ce C~l,pany 200 Ho~m~dow Street PO Box 2999 Hartford, ur 06104-2999 X [] Agent [] ,~dreasee D. Isdellve~addres~diffemntfn~niteml? [] Yes If YES, enter delive~ add~ess below: ;-I No · C°mptete Items 1, 2, and 3. Aiso Complete ifem 4 if Resbtcted Deliver, is deeired. · P~fnt Y°ur name and eddres~ on the reveme ?° that we can m~um the car~ to wu . · Attach this cerd to the beck of th~ ~llptece, °r an the fi'o~t If Space parmlts. ~ford Life Street So× 2999 ~c~o~d, ur 06104-2999 3. Se~ee Type In The Court of Common Pleas of Cumberland County, Pennsylva~nia PALMER MARLENE M v$ SYNERTECH HEALTH SYSTEM SOLUTI File IVo. 2001-06169 To the Court: STATEMENT OF INTENTION TO PROCEED NARLN~qE M. intends to proceed with the above captioned matter. Date: October 25, 2004 Plaintiff MARCUS A McKNIGHT III ESQ IRWIN & McKNIGHT 60 WEST POMFRET STREET CARLISLE PA 17013