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HomeMy WebLinkAbout08-3548 & e' j jz ? A Professional Corporation ..,?ltorYrr? ¢G?ia BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL 3850 Spruce Street Philadelphia, Pennsylvania 19104 Plaintiff V. KENNETH R. GINANNI 209 North Baltimore Avenue Mt. Holly Springs, Pennsylvania 17065 Defendant M- azgg Civil -Fran NOTICE 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 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, TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE PENNSYLVANIA BAR ASSOCIATION Pennsylvania Lawyer Referral Service P.O. Box 186 Harrisburg, Pennsylvania 17108 800-692-7375 ASSESSMENT F DAMAGES EARING: IS _ IS NO REQUIRED -JURY __NON JURY ARBITRATION CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION &0 /4; , & ?e1c fL A PROFESSIONAL CORPORATION 'fa lttoirreya at_r BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL 3850 Spruce Street Philadelphia, Pennsylvania 19104 Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION 74 - 0 1- 2,5- 97 KENNETH R. GINANNI 209 North Baltimore Avenue Mt. Holly Springs, Pennsylvania 17065 Defendant CIVIL ACTION: (1. Contract) 2000/1060 Contract for Goods, Enforcement of Accounts The Plaintiff is the UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL, a corporation not for profit, organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal place of business located at 3850 Spruce Street, Philadelphia, Pennsylvania 19104. 2. The Defendant is KENNETH R. GINANNI, an individual and citizen of the Commonwealth of Pennsylvania, residing at 209 North Baltimore Avenue, Mt. Holly Springs, PA 17065. 3. At the special instance and request of Defendant, Plaintiff did provide certain veterinary services for the benefit of Defendant. 4. Plaintiff did perform said veterinary services in a diligent and professional manner and to the best of its abilities. 5. In return for providing said veterinary services, Defendant agreed to pay the sum of $5,103.25, which was the fair and reasonable price for said services and the price the Defendant agreed to pay. In addition, Defendant promised to pay a monthly service charge on all amounts not paid within thirty (30) days. 6. Plaintiff sent to Defendant, in the regular course of Plaintiffs business, statements reflecting the amount due and payable, and indicating the amount of service charges accruing periodically. A true and correct copy of said statements are attached hereto, made a part hereof and marked Exhibit A. 7. As set forth in the Affidavit of CHRISANN SORGENTONI, the Director of Business & Information Systems, there remains an outstanding balance of $4,231.79 for services rendered, plus $395.40 as monthly services charges calculated through September 21, 2007. A true and correct copy of said Affidavit is attached hereto, made a part hereof and marked Exhibit B. 8. Although demand therefore has been made repeatedly, Defendant has refused and failed to pay the balance due, as set forth above, or any portion thereof. WHEREFORE, Plaintiff demands Judgment against the Defendant in the amount of $4,627.19 with interest at the rate of Eighteen (18%) per annum, from the 21St day of September 2007, to the date of judgment, plus anticipated court costs of $300.00. EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff 2 VERIFICATION I, CHRISANN SORGENTONI, state that I am the Director of Business & Information Systems for the UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL, Plaintiff in this action, and that all statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that the statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. DATE: 1-?- L of Business ******************************************************************************* * C 0 L L E C T I O N -- C L I E N T R E C 0 R D ** 09:00:48 08 OCT 2007 ******************************************************************************* Last.. GINANNI * BillTo * Occupn First. KENNETH * Contct * Emplyr Middle R * Title. Addrl. 209 N. BALTIMORE A* Addrl. * Addrl. Addr2. * Addr2. * Addr2 City.. MT HOLLY SPRINGS * City.. * . City.. State. PA * State. * State Zip... 17065 * Zip... * . Zip... Phone. 717 386-1354 C * Phone. * Phone. 717 730-2224 W Emg Ph 717 486-4411 H Sp Hdl ?? ******************************************************************************* Client Number --> 1195937 Client Name ----> GINANNI ANIMAL/AC Balance ------> 4231.79 Serv Charges -> 395.40 Total Due ----> 4627.19 SPECIES ADMITTED DISCHR'D DISPOSITION CHARGES 791070 01 ------------ OPEN BALANCE ----- ------- ADMISSION FEE 37.00 EMERGENCY EXAMINATION 97.00 E.S.DRUG&EQUIP. CRITICAL 490.00 E.S.HOSP. CRITICAL 108.00 DOLASETRON MESYLATE INJ 12.5MG 70.00 X-RAY CHEST 159.00 DILTIAZEM INJ 5MG/ML 5ML 36.25 HETASTARCH 6% 500ML 65.00 FAMOTIDINE INJ (ML) 18.00 COMPLETE BLOOD COUNT 61.00 CHEM SCREEN 97.00 T4 RIA 40.00 ULTRASOUND--ABDOMEN 320.00 CARDIOLOGY CONSULTATION 75.00 SCREENING ECG 51.00 ECHOCARDIOGRAM-FULL 265.00 FUROSEMIDE TABS 12.5MG 5.00 DIGOXIN TABS 0.125MG 5.00 PIMOBENDAN CAPS 5MG 22.40 PIMOBENDAN CAPS 2.5MG 19.60 ENALAPRIL 10MG 5.00 FLUID ANALYSIS 75.00 COMPLETE BLOOD COUNT 61.00 ICU LAB - C.O.P. 22.00 ICU BLOOD GAS 42.00 cps VED IC T 14.00 RECEI U ELECTROLYTES 42.00 LACTATE 14.00 TRANSPAC IV 34.00 PC, EF?UEN AMPICILLIN INJ 1GM ENROFLOXACIN INJ (M 44.00 G?Rp1N R??YS AS LAW . L) AQUA PAK W TUBING 60.00 22 0 A Rp . . 0 PROF. VET. FEE 71.00 Page 1 BALANCE "HIBIT "A," 1195937 GINANNI ANIMAL/AC SPECIES ADMITTED DISCHR'D DISPOSITION I.C.U. HOSPITALIZATION ICU DRUG & EQUIP CLASS B LIDOCAINE 2%- 05ML DILTIAZEM INJ 5MG/ML 5ML X-RAY CHEST-REPEAT TRANSPAC IV COMPLETE COAGULATION TEST LIDOCAINE 2$ 05ML URINALYSIS, MICRO MEXILETINE CAPS 150MG DILTIAZEM INJ 5MG/ML 5ML TRANSPAC IV DOLASETRON MESYLATE INJ 12.5MG ENROFLOXACIN INJ (ML) AMPICI.LLIN INJ 1GM MULTI LUMEN CATH 7FR X 30CM DILTIAZEM INJ 5MG/ML 5ML PROF. VET. FEE I.C.U. HOSPITALIZATION ICU DRUG & EQUIP CLASS B DOBUTAMINE INJ 250MG DOPAMINE HCL 40MG/ML 5ML DOLASETRON MESYLATE INJ 12.5MG X-RAY ADD'L SURVEY VIEWS ICU LAB - C.O.P. ICU ELECTROLYTES LACTATE ICU ELECTROLYTES LACTATE RENAL PROFILE ICU LAB - C.O.P. LACTATE ICU BLOOD GAS PROF. VET. FEE I.C.U. HOSPITALIZATION ICU DRUG & EQUIP CLASS B METOCLOPRAMIDE INJ 50MG DILTIAZEM TABS 30MG TRANSPAC IV METOCLOPRAMIDE INJ 50MG ICU BLOOD GAS ICU DRUG & EQUIP CLASS B DILTIAZEM INJ 5MG/ML 5ML ENALAPRIL 10MG DILTIAZEM TABS 30MG FUROSEMIDE TABS 12.5MG DIGOXIN TABS 0.125MG MEXILETINE CAPS 150MG ENROFLOXACIN INJ (ML) LIDOCAINE 2t 05ML DOPAMINE HCL 40MG/ML 5ML PIMOBENDAN CAPS 5MG Page 2 CHARGES BALANCE 135.00 135.00 37.50 43.50 97.00 34.00 92.00 375.00 31.00 16.80 14.50 34.00 70.00 120.00 44.00 120.00 14.50 71.00 135.00 135.00 26.25 24.00 70.00 37.00 22.00 42.00 14.00 42.00 14.00 61.00 22.00 14.00 42.00 71.00 135.00 135.00 12.00 7.25 68.00 12.00 42.00 67.50 -14.50 -3.80 -3.30 -4.20 -2.40 -16.00 -6.00 -75.00 -24.00 -12.80 1195937 GINANNI ANIMAL/AC SPECIES ADMITTED DISCHR'D PIMOBENDAN CAPS 791070 01 CANINE 12/27/06 12/29/06 Paymi Accession --------------- --------------------------------- ***** SERVICE CHARGE DETAIL ***** --------------------------------- SCDATE SCAMT 04/20/07 63.47 05/23/07 64.42 06/22/07 65.39 07/26/07 66.37 08/24/07 67.37 09/21/07 68.38 395.40 Page 3 DISPOSITION CHARGES BALANCE 2.5MG -16.80 Dead 5103.25 4231.79 ants to Date $ 871.46 Balance Due $ 4,231.79 ----------------------- ??n r AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA : ss BEFORE ME, the undersigned authority, on this day personally appeared CHRISANN SORGENTONI, the Director of Business & Information Systems for the UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL who hereby first duly sworn on his/her oath deposes and says that the Defendant named in the foregoing suit, KENNETH R. GINANNI is indebted to the UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPTIAL for items and/or services as follows: Description: VETERINARY SERVICES TOTAL CHARGES $ 5,103.25 SERVICES CHARGES THROUGH 09/21/07 $ 395.40 CREDITS AND/OR PAYMENTS: to principal to interest 871.46 other TOTAL AMOUNT DUE $ 4,627.19 That the above account is within the knowledge of said Affiant, just true and accurate, that the same is due and unpaid, and that all lawful and just offsets, payments and credits have been allowed, and that he/she is authorized to make this Affidavit in the capacity stated, and that a systematic record of such account has been kept by the UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSRITAL. DATE: /-/,o Dop Business & SWORN TO AND SUBSCRIBED BEFORE ME THIS to a DAY OF NOTARY PUBLI commoNWEAL'm OF PENN LMAMA 'E DONNA M. STEP$Ak i lotsty PubNc City of Pnilads-l ,?; 3 PNIB. County Commission Tres June 28,2W9 L?JXHIBI7: "B., SORGE IN, Director of nfo on Systems N N C:) W -?C 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03548 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIVERSITY OF PENNSYLVANIA VS GINANNI KENNETH R SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE GINANNI KENNETH R was served upon the DEFENDANT , at 0839:00 HOURS, on the 14th day of June , 2008 at 209 NORTH BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 T)TITTI.-TT /T T TTT XT TT by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 6.00 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 UL1 (? ?b$ ?/ 34.00 06/16/2008 GORDIN & BERGER Sworn and Subscibed to By: J before me this day Deputy Sheri of A.D. &019&v & A PROFESSIONAL CORPORATION ??ltorv d at-rAW11' BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL I hereby certify that I have served a copy of this paper upon all other part' or their attorneys by: SJ eLslar mail ? certified mail ? of r By: CUMBERLAND TY COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO. 08-3548 KENNETH R. GINANNI Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter Judgment in favor of the Plaintiff, UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL, and against the Defendant, KENNETH R. GINANNI, for failure to file an Answer in the above referenced action within twenty (20) days from the date of service of the Complaint, and assess Plaintiffs damages as follows: Amount of Claim $4,627.19 Plus: Less Payments Received Subsequent to filing of Complaint +1,257.00 TOTAL $3,370.19 Plus Court Costs I hereby certify that on the 18th day of August 2008, the attached copy of the Notice required by Pa. R.C.P. No. 237.1 was mailed to the above referenced Defendant. EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff r Af qkt & A PROFESSIONAL CORPORATION ??tto?rtgtfa aG?'au?• BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, CUMBERLAND COUNTY SMALL ANIMAL HOSPITAL COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO. 08-3548 CIVIL TERM KENNETH R. GINANNI Defendant TO: Kenneth R. Ginanni; 209 North Baltimore Avenue, Mt. Holly Springs, PA 17065 Date of Notice: August 18, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PENNSYLVANIA BAR ASSOCIATION Pennsylvania Lawyer Referral Service P.O. Box 186 Harrisburg, Pennsylvania 17108 800-692-7375 4 EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff U.S. POSTAL SERVICE CERTIFICATE OF MAILING n stamps and MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT wire of PROVIDE FOR INSURANCE-POSTMASTER Burr t Received From: GORDIN & BERGER P C _ 1760 MARKET STREET SUITE 600 One piece of ordinary mail addressed to: KENNETH R GINANNI N 209 NORTH BALTIMORE AVENUE o ? 0 -I 1a. °° m MT HOLLY SPRINGS PA 17065 rn O O O A PS Form 3817, Janwry 2001 x a r r° SHERIFF'S RETURN - REGULAR • 1 CASE NO: 2008-03548 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND UNIVERSITY OF PENNSYLVANIA VS GINANNI KENNETH R SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the GINANNI KENNETH R was served upon DEFENDANT at 0839:00 HOURS, on the 14th day of June , 2008 at 209 NORTH BALTIMORE AVENUE MT HOLLY SPRINGS, PA 17065 by handing to KENNETH GINANNI a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.00 Affidavit .00 Surcharge 10.00 .00 34.00 Sworn and Subscibed to So Answers: 00, 7 R. Thomas Kline 06/16/2008 GORDIN & BERGER By: d,- 1 before me this day Deputy Sheri of A.D. ?` ft... &Q?d1;7, & ?? A PROFESSIONAL CORPORATION ?>!tlor ,- at-r- BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street - Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL Plaintiff V. KENNETH R. GINANNI Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3548 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF PHILADELPHIA : ss EDWARD L. BERGER, ESQUIRE, being duly sworn according to law, hereby deposes and says that I am the attorney for the Plaintiff in the above captioned action, and that the following Defendant is not in the Military Service of the United States of America or any State or Territory thereof, or its allies, and that the Defendant is not in any manner subject to the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended: Kenneth R. Ginanni 209 N. Baltimore Avenue Mt. Holly Springs, PA 17065 SWORN TO AND SUBSCRIBED BEFORE ME THIS 2ND DAY OF JUNE , „ 2009. EDWARD L. BERGER, ESQUIRE Attorneys for Plaintiff NOTARY PUBLIC NOTARIAL SEAL DONNA M, STEPHAN, Notary Public City of Philadelphia, Phila. Courdy My Commission_Exuires June 25, 2009 OF Txr t, ONOTARY 2009 JUN -9 AM 8: 04 yOUNTY PENNSYLVAN IA $ Ij.oo Po ATr/ Mvv ! 3q a4 Oc?tL wwj&c l ArAT & ?? A PROFESSIONAL CORPORATION ./lttorn?/d aG?¢ur BY: EDWARD L. BERGER, ESQUIRE Identification No. 34116 1760 Market Street • Suite 600 Philadelphia, Pennsylvania 19103 (215)564-2031 FAX (215)972-5390 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL Plaintiff V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION KENNETH R. GINANNI Defendant NO. 08-3548 ASSESSMENT OF DAMAGES AND NOW, to wit, this _2 day of ?jUr)p , 2009 Judgment is entered in favor of the above referenced Plaintiff, and against KENNETH R. GINANNI, the above referenced Defendant, for failure to file an Answer and Plaintiffs damages are assessed in the sum of $3,370.19. F jar- -- Prothonotary .. . 4. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS To: Mr. Kenneth R. Ginanni 209 N. Baltimore Avenue Mt. Holly Springs, PA 17065 UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. KENNETH R. GINANNI No. 08-3548 Defendant Notice 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. Judgment by Default ? Money Judgment rofhon0 ? Judgment in Replevin ? Judgment for Possession L.19/09 ? Judgment on Award of Arbitrators ? Judgment on Verdict ? Judgment on Court Findings If you have any questions concerning this notice, please call: ATTORNEY EDWARD L. BERGER Esquire (Insert Attorney's Name) at this telephone number: 215-564-2031 10-232 (Rev. 2100) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL V. KENNETH R. GINANNI PNC BANK -and- Plaintiff Defendant Garnishee File No. 08-03548 Amount Due $3,370.19 Interest 06/09/09 Atty's Comm Costs TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, 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. PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter to the Sheriff of CUMBERLAND County, for debt, interest and costs upon the following described property of the Defendant(s) All contents of Defendant's residence, including but not limited to furniture, clothing, iewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, stereo equipment, tools and any other property subiect to levy located at 209 N. Baltimore Avenue, Mt. Holly Springs, PA 17065 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) Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in the possession of the Garnishee belonging to the Defendant, KENNETH R. GINANNI. and all other property of the Defendant(s) in the possession, custody or control of the said Garnishee(s). (Indicate) Index this writ against the Garn' e(s) as a lis pendens a ainst real estate of the Defendant s) described in the attached exhibit. DATE: 1 ? Signature: Print Name: Edward L. Berger, Esquire Address: Gordin & Berger, P.C. 1760 Market Street, Suite 600 Philadelphia, PA 19103 Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (Pa. R.C.P No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. FILED-OF SCE THE PROTHONOTARY 2010 JAN -7 PM 3: 08 CUt } t,OUN1Y PENNSYLVANIA. *a4.50 PO ATT`l 34. o o CBF 78.50 14. oo a . so ., 153. 50 - Po ATW -$a. oo IJve(q • 5o I.L ciew 135(p7$ QT* am 951 L?>i+ c? &P ??ecl WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3548 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIVERSITY OF PENNSYLVANIA, SMALL ANIMAL HOSPITAL, Plaintiff (s) From KENNETH R. GINANNI, 209 N. Baltimore Avenue, Mt. Holly Springs, PA 17065 (1) You are directed to levy upon the property of the defendant (s)and to sell all contents of defendant's residence, including but not limited to furniture, clothing, jewelry, electronic equipment, electrical appliances, kitchen utensils, silverware, televisions, stereo equipment, tools and any other proprty subject to levy located at 209 N Baltimore Avenue, Mt. Holly Springs, PA 17065. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PNC BANK, 2 W. Pine Stree, Mt. Holly Springs, PA 17065 Checking accounts, savings accounts, monies on deposit, safety deposit boxes, or any other personalty or realty which may be in th possession of the Garnishee belonging to the Defendant. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,370.19 L.L.$.50 Interest from 6/9/09 - to be determined Atty's Comm % Due Prothy $2.00 Atty Paid $153.50 Other Costs Plaintiff Paid Date: 1/07/10 i Davi D. Buell, ProthonioRdy (Seal) By: Deputy REQUESTING PARTY: Name EDWARD L. BERGER, ESQUIRE Address: GORDIN & BERGER, PC 1760 MARKET STREET, SUITE 600 PHILADELPHIA, PA 19103 Attorney for: Plaintiff Telephone: 215-564-2031 Supreme Court ID No. 34116 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson > L Sheriff I `C ' Jody S Smith t 1 v Chief Deputy 2 I D J''' 22 Edward L Schorpp Solicitor r- t'C 1 w4 University of Pennsylvania, Small Animal Hospital Case Number vs. 2008-3548 Kenneth R Ginanni SHERIFF'S RETURN OF SERVICE 01/15/2010 02:20 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15, 2010 at 1420 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kenneth Ginanni, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, b5 handing to Kimberlee Borosky, Financial Salees Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. NOAH CLINE, DEPUTY January 21, 2010 SO ANSWERS, RON ANDERSON, SHERIFF (c -0untySu4r1, Shen?t Te,^os:;ft Inc `, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~ Sheriff ~F P'~?r ~-`f~?/~ ~9autr of ~uu~brrf~~~ Jody s smith ~ 10 AUG 3 l AM 8~ 2 7 Chief Deputy ~ ~,~.~~ ~ Richard W Stewart '•~ CUMBF~~~ ~~ ~~~ Solicitor ~~,~,Er~,1E s~s~irr P~~/ University of Pennsylvania, Small Animal Hospital Case Number vs. Kenneth R Ginanni 2008-3548 SHERIFF'S RETURN OF SERVICE 01/15/2010 02:20 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 15, 2010 at 1420 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kenneth Ginanni, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kimberlee Borosky, Financial Salees Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. 01/28/2010 02:11 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on January 28, 2010 at 1339 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Kenneth R. Ginanni, by making known unto Kenneth R. Ginanni, at 209 N Baltimore Avenue, Mt. Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on February 1, 2010. 08/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $145.37 SO ANSWERS, .~ August 30, 2010 RON R ANDERSON, SHERIFF aron R. Lantz ~-©a ~.~. a ~~P~ (c} GountySuite Sheriff. Teleosoft, Inc.