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HomeMy WebLinkAbout10-3549 COHEN, SEGLIAS, PALLAS GREENHALL & FURMAN, P.C. By: Lane F. Kelman Identification No. 75723 By: Alexander F. Barth Identification No. 91558 30S.17 th Street, 19th Floor Philadelphia, PA 19103 (215) 564-1700 COOK'S SERVICE COMPANY, INC. 300 Industrial Drive Avondale, PA 19311 Plaintiffs, V. MHB DENTAL SERVICES, INC. 275 Wilmington -West Chester Pike Chadds Ford, PA. 19317 T 'v t`'-,' a L E !? l y Attorneys for Plaintiff Cook's Service Company, Inc. Court of Common Pleas Cumberland County Civil Action No. td -,3,r4 V? e't u ?l,7&y,- Attorney for Plaintiff: Alexander F. Barth Cohen, 'Seglias, Pallas, Greenhall & Furman P.C. 30 S. 17th Street, 19th Floor, Philadelphia, PA (215) 564-1700 Attorney for Defendant: Date: May 27, 2010 Luke F. McLaughlin, Esquire Reynolds, McLaughlin, Josel & Reynolds 621 Dekalb Street, Norristown YA 19401 Alexander F. Barth, Esquire CX) ??? tG? A14 COHEN, SEGLIAS, PALLAS GREENHALL & FURMAN, P.C. By: Lane F. Kelman Identification No. 75723 By: Alexander F. Barth Identification No. 91558 30S.17 1h Street, 19th Floor Philadelphia, PA 19103 (215) 564-1700 Attorneys for Plaintiff Cook's Service Company, Inc. COOK'S SERVICE COMPANY, INC. Court of Common Pleas 300 Industrial Drive Cumberland County Avondale, PA 19311 , Plaintiffs, V. Civil Action No. MHB DENTAL SERVICES, INC. 275 Wilmington -West Chester Pike Chadds Ford, PA. 19317 PRAECIPE TO TRANSFER JUDGMENT TO THE PROTHONOTARY: Kindly transfer and enter the judgment against defendant/judgment debtor, MHB Dental Services, Inc. and in favor of plaintiff/judgment creditor Cook's Service Company, Inc. in the amount of $22,567.00 in accordance with the attached exemplified or certified records of Prothonotary, Court of Common Pleas, Montgomery' County, No. 2009-00059. Dated: May 27, 2010 COHEN, SEGLIAS, PALL 3, GRENLL AN, P.C. Alexander Frth Attorneys for Plaintiff/Judgment Creditor, Cook's Service Company, Inc. 2 14 CERIFICATE OF SERVICE I, Alexander F. Barth, Esquire, hereby certify that a true and correct copy of the Praecipe to Transfer Judgment has been served via certified mail and first class, United States mail, pre- paid postage to the following: Luke F. McLaughlin, Esquire Reynolds, McLaughlin, Josel & Reynolds 621 Dekalb Street Norristown, PA 14401 Date: May 27, 2010 06360-015 3 #987927-v 106924-0003 Montgomery County Back to Search > Case #2009-00059 t- Case Details Case Number 2009-00059 Commencement Date 1/2/2009 Case Type Certification of Judgment PFA Number Caption Plaintiff COOKS SERVICE COMPANY INC Caption Defendant MHB DENTAL SERVICES INC Lis Pendens Indicator No Status 1 Judge Parcel Number Remarks DELAWARE COUNTY ^ Sealed No Docket Date Range: All dockets e Plaintiffs Page 1 of 1 CER 1 WIED FROM THE RECORDS OF THE PROTHONOTARY, COURT OF COMMON PLEAS, MONTGOMERY COUNTY, PA. MARK" P DATE: ?f .? l Zb ? I D --- Judgment certified in the amount ci Z Z S67 or, In favor of Plaintiff(s) Co" Ser'Ilc-e L?"gn4 T"c._ And against MM Defendant(s) 5Qr,?e5 Dv- Date 5 {Zdlla Name. COOKS SERVICE COMP Address Country Counsel Noti Sequence ANY INC 300 INDUSTRIAL DR AVONDALE, PA 19311 UNITED STATES UNITED STATES WAHN, CHARLES F Yes 1 0 Defendants Name Address MHB DENTAL SERVICES INC 275 WILMINGTON Country UNITED STATES Counsel Notify WEST CHESTER PIKE Yes CHADDS FORD, PA 19317 UNITED STATES R Garnishaas 5e uence Name Address AETNA 980 JOLLY ROAD ntrv Co Attomev BLUE BELL, PA 19422 UNITED STATES UNITED STATES DELTA DENTAL ONE DELTA DRIVE UNITED STATES MECHANICSBURG, PA 17055 UNITED STATES I-J Dockets 4 (es (es , Seq. Filing Date Docket._T Docket Text 0 1/2/2009 Certificatigment DELAWARE COUNTY Sealed N 1 2 1/2/'1009 1/2/2009 Affidavit/Ce of Service of ee Entryof Ace PRAECIPE TO TRANSFER JUDGT & ENTRY OF APPEAR SENT ON 12/2/2008 OF CHARLES F WAHN FOR PLTF o No 3 1/2/2009 S Affidavit o No 4 1/212009 Notice 23ent Required Document Mailed No 5 4119/2010 Praeci e f ti & Wri I No p u on t ssued with Gamishee AETNA GARNISHEE 6 4/1912010 Interro at No g AETNA N 7 4/19/2010 Praecipe ftion & Writ Issued with Gamishee DELTA DENTAL GARNISHEE o N 8 4119/2010 Interroga tories DELTA DENTAL ; o 9 5/13/2010 (Internal Use Only) Served AETNA INC ON 517/10 o No _ J U Jud ments Plaintiff_ Defendant ]tate- Amoun t MHB DENTAL SERVICES INC 009 22,567.00 t- Archive Locati s I3 Linked Cases Copyright © 2008-2010 Paperless Solutions, Inc. All rights reserved. http://webapp.montcopa.org/PSI/Viewer/Detail.aspx?oq=aWQ9MjAwNjU 1 NzcOJmVudGI... 5/20/2010 e > COHEN, SEGLIAS, PALLAS GREENHALL & FURMAN, P.C. By: Lane F. Kelman Identification No. 75723 By: Alexander F. Barth Identification No. 91558 30 S. 17"' Street,l9`h Floor Philadelphia, PA 19103 (215) 564-1700 Attorneys for Plaintiff Cook's Service Company, Inc. COOK'S SERVICE COMPANY, INC. Court of Common Pleas 300 Industrial Drive Cumberland County Avondale, PA 19311 . Plaintiffs, v, Civil Term No. 10-3549 MHB DENTAL SERVICES, INC. 275 Wilmington -West Chester Pike Chadds Ford, PA. 19317 Defendant ;-~ ~ N o And ,~~~ c~ -~. r~ • ~- ~ :~ c7 -.-, .~ Delta Dental ~~ ~ One Delta Drive r- °=" Mechanicsburg, PA 17055 ~ ~ Garnishee rv .~ ~ c..~ ~ ., PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE FOR WANT OF AN ANSWER TO INTERROGATORIES IN ATTACHMENT, ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against garnishee(s) above named only, with leave to assess damages. ca -ry R~r; ~~ ~~~p -~c~ -:-~ ~~ --E'-~ Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: $ I~.oO P b Amy ~'~3s8t1 ~ a~19~3~b N~hc~ I~b~-~ 1. The precise last known addresses of the parties are as follows: COOK'S SERVICE COMPANY, INC., 300 Industrial Drive, Avondale, PA 19311 MHB DENTAL SERVICES, INC., 275 Wilmington/West Chester Pike, Chadds Ford, PA. 19317 DELTA DENTAL, One Delta Drive, Mechanicsburg, PA 17055 2. Garnishee, Delta Dental was served with a writ of execution and interrogatories in attachments by the Sheriff of Cumberland County on June 15, 2010. A copy of the Sheriff s Return of Service is attached as Exhibit A. 3. A notice of intention to enter judgment by default was mailed to Delta Dental, as garnishee, after default occurred, and at least ten days prior to the date of filing this praecipe. A copy of the notice is attached as Exhibit B. 4. Delta Dental, is a Corporation and as such is not in the military service of the Unites States or otherwise with in the coverage of the Soldiers and Sailors Relief Act and is over 18 years of age. THIS ~' date of _ ~~p,,(~pr , 2010, Judgment is entered in favor of Plaintiff, Cooks' Service Company, Inc. and against Delta Dental, Garnishee, by default for want of an Answer with Leave to Assess Damages. lexander F. arth, Esquire Counsel for Cooks' Service Company, Inc. ~yid ~~uell ~ Prothonotary ~~ ~~he ~q ~, y-o3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff coaptr of utttrtbrr~,~~~ Jody S Smith b Chief Deputy ~~ -~ Richard W Stewart "~~~~~~~ SOiICItOf OFFICE OF THE SH$RIFF Cook's Service Company, Inc. Case Number vs. MHB Dental Services, Inc. 2010-3549 SHERIFF'S RETURN OF SERVICE 06/15/2010 02:25 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2010 at 1420 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: MHB Dental Services, Inc., in the hands, possession, or control of the within named garnishee, Delta Dental at 1 Delta Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Rebecca L. Tackett, Manager, 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. The writ of execution and notice to defendant was mailed on June 16, 2010 to MHB Dental Services, Inc. at 275 Wilmington-West Chester Pike, Chadds Ford, PA 19317. SO ANSWERS, June 16, 2010 RON R ANDERSON, SHERIFF 13y TIMOT Y LACK, DEPUTY SHERIFF (c) CounlySuita Sheriff. TeleoSOR. Ir1c. ~~h ~3 b~ COHEN, SEGLIAS, PALLAS GREENHALL & FURMAN, P.C. By: Alexander F. Barth Identification No. 91558 30 S. 17"' Street, 19"' Floor Philadelphia, PA 19103 (215) 564-1700 COOK'S SERVICE COMPANY, INC. v. Plaintiffs, Attorneys for Plaintiff Cook's Service Company, Inc. Court of Common Pleas Cumberland County Civil Term No. 10-3549 MHB DENTAL SERVICES, INC. Defendant And Delta Dental Garnishee TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT TO: Delta Dental One Delta Drive Mechanicsburg, PA 17055 Date: September 9, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR ANSWERS TO THE INTERROGATORIES INATTACHMENT SERVED ON JUNE 15, 2010. 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 PAPER TO YOUR 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: Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 Fax: (717) 249-9266 COHEN, SEGLIAS, LLA GREEN .C. B~ Alexande .Barth, s ire Dated: September 9, 2010 #1079545-v1 06924-0003 COHEN, SEGLIAS, PALLAS GREENHALL & FURMAN, P.C. By: Lane F. Kelman Identification No. 75723 By: Alexander F. Barth Identification No. 91558 30S.17 th Street, 19th Floor Philadelphia, PA 19103 (215) 564-1700 COOK'S SERVICE COMPANY, INC. 300 Industrial Drive Avondale, PA 19311 Plaintiffs, V. MHB DENTAL SERVICES, INC. 275 Wilmington -West Chester Pike Chadds Ford, PA. 19317 Defendant And Delta Dental One Delta Drive Mechanicsburg, PA 17055 Garnishee ,? Apt eta Attorneys for Plaintiff Cook's Service Company, Inc. Court of Common Pleas Cumberland County Civil Term No. 10-3549 PRAECIPE FOR DISMISS JUDGMENT AGAINST GARNISHEE. DELTA DENTAL TO THE PROTHONOTARY: Kindly dismiss the judgment entered against garnishee, Delta Dental only in the above: captioned matter. COHEN, SEGLIAS, PALLAS, GREENHALL & 71A N, P.C. lex V. By: F. Barth, Esquire Attorney for Plaintiff .. vp ck ? s?o-a$ 2-?aso?'? CERTIFICATE OF SERVICE I, Alexander F. Barth, Esquire, hereby certify that a true and correct copy of the Praecipe to Dismiss the Judgment Against Garnishee, Delta Dental was served via first class United States mail, pre-paid postage upon the following: MHB Dental Services, Inc. 275 Wilmington -West Chester Pike Chadds Ford, PA. 19317 Delta Dental One Delta Drive Mechanicsburg, PA 17055 Alexan d erT. Barth, Esquire Attorney for Plaintiff, Cook's Services Co., Inc. #1125094-v1 06924-0003