HomeMy WebLinkAbout11-0025
e
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES,
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
No. - 5 ~viITP,FN1
TYPE OF PLEADING:
PRAECIPE TO FILE and INDEX
FOREIGN JUDGMENT
TYPE OF CASE: CIVIL
Defendant. Transfer of Foreign Money Judgment
: Pursuant to Uniform Enforcement of
: Foreign Judgments Act, 42 Pa. C.S.
~ 4306
FILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR
FOR THIS PARTY:
John A. Snyder, Esquire
PA I.D. No. 66295
McQUAIDE BLASKO, INC.
811 University Drive
State College, PA 16801
PH# (814) 238-4926
FAX#(814) 238-9624
~a4.oo Po p~f
c~ ~ay~a~
~~ ass ~a9
Nehct ~~~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES,
No. ~"o~J CiWt`fur-
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
PRAECIPE TO FILE AND INDEX FOREIGN JUDGMENT
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Pursuant to the Uniform Enforcement of Foreign Judgments Act, 42 Pa. C.S. §
4306, kindly enter judgment in favor of Plaintiff, ENTERPRISE MEDICAL SERVICES,
and against the Defendant, CENTRAL PENNSYLVANIA PULMONARY
ASSOCIATES, LLC, in the amount of $7,709.00, in accordance with the attached
certified copies of the docket entries and judgment originally entered at Docket No.
l OSL-AC26893 of the Circuit Court of St. Louis County, in the State of Missouri, and
index said judgment against the Defendant.
McQUAIDE BLASKO, INC.
Dated: Decembe'~ , 2010
By: ~ .
hn A. Snyder, Esqu re
Pa. I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
In the
CIRCUIT COURT
of St. Louis County, Missouri
Plaintiff(s)
vs. ~ f
Defendant(s)
~~~~~L' lGts 1 ~S~
~i~
Dat
.~
ase Number
J~ v ~'
Division
JUDGMENT IN DEFAULT
For File Stamp Only
~~~
.IRAN INI, ~I~M~f~
L e ~~~tiIT C;,~RIt, ST, l~U s ~JN'6~~
Plaintiff(s) appear(s) in person (and by attorney). The defendant(s) although called three times appear(s) not.
The court finds that the defendant(s) (is)(are) in default. This cause now being submitted to the court upon the
pleadings and evidence, and the court being fully advised in the premises finds that the plaintiff(s) (is) (are)
entitled to a default judgment.
Wherefore, it is ORDERED, ADJUDGED, and DECREED that the plaintiff(s) have and 'recover from the
defendant(s) as follows:
$ ~ ~ (~~ U-~-, Principal
$ "-~ Interest
$ ~] O~ Attorney's fees
$ ~t ]UR ~ G`~ Total plus court costs
SO ORDERED:
Judge ~ 1
'That, to the best of the affiant's knowledge and
belief, the defendant(s) (is) (are) employed in
civilian life and that the defendant(s) (is) (are)
not now engaged in the military service of the
United States.
~lt~~ 2 ~
A orney Bar No.
. I l~.S~- S 35a S~ ~ j ~
Address Z U2.._.
y Phone No. ~(~~ 1 Fax No.
Sworn befgt~ meek '"t -~ - l
Deputy CI
I certify and attest that the above is a true copy of the original record of the Court in case
number ~OSL -AL zlo~93 as it appears on file in my office.
i ''
er i `
~~ ~~~_ "~
Issued
12-, q f I b
JOAN M. GILMER, Circuit Clerk
St. Louis County Circuit Court
By
~~ ~~~,
Deputy Clerk
CCOPR36 Rev. 06/00
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES, No. ~ - S Cc•'Yal ~~~~'~`
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
INDEX OF MISSOURI DOCKET ENTRIES
Dlocket Entries Results
Page 1 of 1
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21~# Jud~ciad Gircl.at (St. Lot,li Count )
Case Partla^s i €~ ~ket ' GMr e, Judrr#s gger~ice f~r~s ~~` Sat~esi~ed _ Ciwi ~~~G~mantsf .
Nc~der RWtowrt~pa ~ _ _ _._._.
~ntri~s ~e~etis ~ I~arr~tetion ~ ! ~ F#rter~ir~s >R Trif~t: ..tw~rncrns Execat~an
10SL-AC26893 -ENTERPRISE MED SERVICES V CENTRAL PENN PULMONARY
This information is provided as a service and is not considered an official court record.
Displaying 1 thru 6 of 6 records for all dockets retumed for case 10SL-AC26893.
07126!2010 Docket Entry: Judge Assigned
Text: 33W
Docket Entry: Pet Filed in Associate Ct
08/11/2010 Docket Entry: Hearing Scheduled
Associated Docket Entries: 09/08/2010 -Default Judgment
Associated Events: 09/08/2010 , 09:00:00 -Hearing
Docket Entry: Summons Issued-Associate
Text: Document ID: 10-ASOS-1114, for CENTRAL PENNSYLVANIA PULMONARY
ASSOCIATES LLC.
09/0812010 Docket Entry: Default Judgment
Associated Docket Entries: 08/11/2010 -Hearing Scheduled
Associated Events: 09/08/2010 , 09:00:00 -Hearing
Docket Entry: Judgment Entered
Text: PLT TO RECOVER OF DFT PRINCIPAL, ATTY FEES AND COURT COSTS. AFFIDAVIT
FILED SO ORDERED JUDGE BRENDA LOFTIN
Displaying 1 thru 6 of 6 records for all dockets retumed for case 10SL-AC26893.
Case.net Version 5.9.4.2 Return to Tap of Page Released 10/01/2010
https://www.courts.mo.gov/casenet/cases/searchDockets.do 12/13/2010
Judgment_Details
lPage 1 of 1
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21st Judicial Circuit St, Loins Coa~nt
i;,~ Parties ~ ( e4 ~ Ghar®es:Judgrn~r-ts ' ~ervice 4 ~il~gs ~ Sct~ey ,, Cire~# ~ Gentai ~j
H~t : ~ttott~r>< I '~s 8 serda~~xs ~ I Qtrmi-t~n j tp~ea Nc~rir~s tr ~'siatt . ~rraa'nts ; EaE~ut~on
10SL-AC26893 -ENTERPRISE MED SERVICES V CENTRAL PENN PULMONARY
This information is provided as a service and is not considered an official court record.
Judgment
CENTRAL
Date: 09/08/2010 Description: Judgment Entered Against: PENNSYLVANIA
PULMONARY
ASSOCIATES LLC
Amount of ~~ 709.00 Date of Satisfaction: not yet on file
Judgment:
Text: PLT TO RECOVER OF DFT PRINCIPAL, ATTY FEES AND COURT COSTS.
AFFIDAVIT FILED SO ORDERED JUDGE BRENDA LOFTIN
Case.net Version 5.9.4.2 Return to Tarp of Pape Released 10/01/2010
https://www.courts.mo.gov/casenet/cases/judgements.do 12/13/2010
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES,
No.
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
AFFIDAVIT IN SUPPORT OF PRAECIPE TO TRANSFER JUDGMENT
COMMONWEALTH OF PENNSYLVANIA }
} ss:
COUNTY OF CENTRE }
I, JOHN A. SNYDER, ESQUIRE, being duly sworn according to law, depose and
state:
1. I am an attorney in good standing, admitted to practice in the courts of this
Commonwealth, and am local counsel of record for the Plaintiff-judgment creditor,
Enterprise Medical Services, in the above-captioned matter.
2. I am authorized to make this Affidavit on behalf of the Plaintiff.
3. The address of the Plaintiff is 714 Spirit 40 Park Drive, Suite 125,
Chesterfield, Missouri 63005.
4. The last-known address of the Defendant, Central Pennsylvania Pulmonary
Associates, LLC, is 2250 Millennium Way, Suite 400, Enola, Pennsylvania 17025.
5. The judgment reflected by lOSL-AC26893 of the Circuit Court of St. Louis
County, in the State of Missouri is in the amount of $7,709.00 and is valid, enforceable
and unsatisfied.
~~
~. ~~
Jo A. Snyder
SWORN to and Subscribed
S'r
before me this ~ day
of ll~ 0.
N
rpnante A. P~d~ey, Notary Public
Yale Colis~a Boro, Centre
c«nmrsaion Exora, u~a .
Page 2 of 2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES, No.
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Plaintiff s Praecipe to File and
Index Foreign Judgment with Affidavit in Support of Praecipe to Transfer Judgment and
Notice of Entry of Transferred Judgment in the above-captioned matter was served by
U.S. ls` Class Mail, postage prepaid, on this,~~day of December, 2010, to the
attorneys/parties of record:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
McQUAIDE BLASKO, INC.
By: ~ ~ -
J hn A. Snyder, Esquire
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
i
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ENTERPRISE MEDICAL
SERVICES, No. 11 -o?S Ctd~l T~+'~
Plaintiff,
v. :
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
NOTICE OF ENTRY OF TRANSFERRED JUDGMENT
TO: Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
PLEASE TAKE NOTICE that a judgment in the amount of $7,709.00 has been
entered against you in the above-captioned matter, upon transfer of the same judgment
from Docket No. IOSL-AC26893 of the Circuit Court of St. Louis County, in the State of
Missouri.
Pr otary
Date: ~ ' -!'o~(
FILED-OFFICE
OF THE PROTHONOTAR Y
2011 APR - I PM I : 28
CU PENNS LVCOUNTY
A IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES,
No. 11-25
Plaintiff,
v.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
TYPE OF PLEADING:
CERTIFICATE OF SERVICE
TYPE OF CASE: CIVIL
Transfer of Foreign Money Judgment
Pursuant to Uniform Enforcement of
Foreign Judgments Act, 42 Pa. C.S.
§ 4306
FILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR
FOR THIS PARTY:
John A. Snyder, Esquire
PA I.D. No. 66295
McQUAIDE BLASKO, INC.
811 University Drive
State College, PA 16801
PH# (814) 238-4926
FAX#(814) 238-9624
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES, No. 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Plaintiff's Interrogatories in aid of
execution to Defendant in the above-captioned matter was served by U.S. I" Class Mail,
postage prepaid, on this 3 0 day of March, 2011, to the attorneys/parties of record:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
McQUAIDE BLASKO, INC.
By: 6? 0. T
Johr A. Snyder, Esquire
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
FlLFD-OFRC;F
CIF p f?O iaOa.r.jr,k :`
?U 91 JUN 13 PM 1 ? 31
C`!.fSE?Lk?ID C;GC??-l
S Y; yt -1
iNTHE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES,
V.
Plaintiff,
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
9. o c>
.2. SG -
? SL . oo - ., ..
0.2.66 ?a
C- K=*f- /aL 87S
Defendant.
No. 11-25
TYPE OF PLEADING:
PRAECIPE FOR WRIT OF
EXECUTION
TYPE OF CASE: CIVIL
Transfer of Foreign Money Judgment
Pursuant to Uniform Enforcement of
Foreign Judgments Act, 42 Pa. C.S.
§ 4306
FILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR
FOR THIS PARTY:
John A. Snyder, Esquire
PA I.D. No. 66295
McQUAIDE BLASKO, INC.
811 University Drive
State College, PA 16801
PH# (814) 238-4926
FAX#(814) 238-9624
PA .2 1.614(44=.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES, No. 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue writ of execution in the above matter,
(1) directed to the sheriff of Cumberland County;
(2) against Central Pennsylvania Pulmonary Associates, LLC, 2250
Millennium Way, Suite 400, Enola, PA 17025, Defendant; and
(3) against Graystone Bank, 417 Village Drive, Carlisle, PA 17015, Garnishee;
(4) and enter this writ in the judgment index
(a) against Central Pennsylvania Pulmonary Associates, LLC,
Defendant, and
(b) against Graystone Bank, as Garnishee,
as a lis pendens against real property of the Defendant.
(5) Amount due
Interest from 9/8/2010
Costs to be added
Total
Dated: June , 2011
$7,709.00
$ 693.81
$1,493.00
$ "895.81
McQUAIDE BLASKO, INC.
By: ? . C _.
-JAL . Snyder, Esquir
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-25 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ENTERPRISE MEDICAL SERVICES, Plaintiff (s)
From CENTRAL PENNSYLVANIA PULMONARY ASSOCIATES, LLC., 2250 MILLENNIUM
WAY, SUITE 400, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GRAYSTONE BANK, 417 VILLAGE DRIVE, CARLISLE, PA 17015
GARNISHEE(S) as follows:
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 $7,709.00
Interest FROM 9/8/2010 - $693.81
L.L. $.50
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: JUNE 13, 2011
(Seal)
Rl~QUFSTING PARTY:
Name JOHN A. SNYDER, ESQUIRE
Address: MCQUAIDE BLASKO, INC.
811 UNIVERSITY DRIVE
STATE COLLEGE, PA 16801
Attorney for: PLAINTIFF
Telephone: 814-238-4926
Due Prothy $2.00
Other Costs
David D. u 1, Prothonot
By:
Deputy
Supreme Court ID No. 16801
0, T
X31! JU 1 3 PM P:
t"U"'18E8LAi,4D '3
PENNSYLVAP11p
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES,
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
No. 11-25
TYPE OF PLEADING:
CERTIFICATE OF SERVICE
TYPE OF CASE: CIVIL
Transfer of Foreign Money Judgment
Pursuant to Uniform Enforcement of
Foreign Judgments Act, 42 Pa. C.S.
4306
FILED ON BEHALF OF:
: PLAINTIFF
COUNSEL OF RECORD FOR
FOR THIS PARTY:
John A. Snyder, Esquire
PA I.D. No. 66295
McQUAIDE BLASKO, INC.
811 University Drive
State College, PA 16801
: PH# (814) 238-4926
FAX#(814) 238-9624
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES, No. 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Plaintiff's Interrogatories Directed
to Graystone Bank in the above-captioned matter was served by U.S. I" Class Mail,
postage prepaid, on this day of June, 2011, to the attorneys/parties of record:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
McQUAIDE BLASKO, INC.
By: 0 ..
Jo A. Snyder, Esq re
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
::ODMA\PCDOCS\DOCS LIB2M9735\ t
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES,
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
No. 11-25
CERTIFICATE OF SERVICE
11 JVN
??? !ALP uUrr°a .x
t ,. NHS ?
V,A T ?:;.
I hereby certify that a true and correct copy of Plaintiff's Praecipe for Writ of
Execution in the above-captioned matter was served by U.S. I" Class Mail, postage
prepaid, on this -1_ day of June, 2011, to the attorneys/parties of record:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
McQUAIDE BLASKO, INC.
By:
Jo A. Snyder, Esq ire
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson '
Sheriff
01111 of rrrrtt"pf
Jody S Smith ftd 2:M
0 i w
r--
Chief Deputy
Richard W Stewart
Solicitor s -: >
CJ
?
7t
+- F3
Enterprise Medical Services, Inc.
vs.
Central Pennsylvania Pulmonary Associates, LLC
Case Number
2011-25
SHERIFF'S RETURN OF SERVICE
06/16/2011 02:03 PM - Michael Barrick, Deputy, who being duly sworn according to law, attached as herein
commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands,
possession, or control of the within named garnishee, Graystone Bank, 417 Village Drive, South Middleton
Township, Carlisle, PA 17015, Cumberland County, by handing to JENEAN FINLEY- BANKING REP.,
personally 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 21, 2011 to Central Pennsylvania
Pulmonary Assoociates, LLC, 2250 Millennium Way, Ste 400, Enola, PA 17025.
SO ANSWERS,
June 20, 2011 RON R ANDERSON, SHERIFF
Michael Barrick, Deputy
(cj countySuite Sherd, Ieieosc t. Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
ENTERPRISE MEDICAL SERVICES,
Plaintiff :
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant
and
GRAYSTONE BANK,
Garnishees
NO.: 11-25
ANSWERS TO INTERROGATORIES
IN ATTACHMENT ADDRESSED TO GARNISHEE,
GRAYSTONE TOWER BANK
By:
?i Ci
zo z°'
3> O fl
--? N) D
.-? cT ?a
N*lanie L. Vanderau, Esq.
Associate Counsel
Graystone Tower Bank
112 Market Street
Harrisburg, PA 17101
(717) 728-2628
Attorney for Garnishee,
Graystone Tower Bank
1
GARNISHEE'S ANSWERS TO INTERROGATORIES
At the time you were served or at any subsequent time did you owe the Defendant any
money or were you liable to the Defendant on any negotiable or other written instrument,
or did he claim that you owed him any money or were liable to him for any reason?
ANSWER: Graystone Tower Bank maintains the following account for
Central Pennsylvania Pulmonary Associates, LLC:
Checking account number XXXXXX2709. The balance in the
account on June 16, 2011 was $1,858.19.
2. At the time you were served or at any subsequent time was there in your possession,
custody or control of yourself and one more other persons any property of any nature
owned solely or in part by the Defendant?
ANSWER: No.
3. At the time you were served or at any subsequent time did you hold legal title to any
property of any nature owned solely or in part by the Defendant or in which the
Defendant held or claimed any interest?
ANSWER: No.
4. At the time you were served or at any subsequent time, did you hold as a fiduciary any
property in which Defendant had an interest?
ANSWER: No.
5. At any time before or after you were served, did the Defendant transfer or deliver any
property to you or to any person or place pursuant to your directions or consent and if so,
what was the consideration thereof?
ANSWER: No.
6. At any time after you were served did you pay, transfer or deliver any money or property
to the Defendant or to any person or place pursuant to the Defendant's direction or
otherwise discharge any claim of the Defendant against you?
ANSWER: No.
2
Respectfully submitted,
GRAYSTONE TOWER BANK -?Waw? By: /'e
anie L. anderau
Attorney I.D. No. 203167
112 Market Street
Harrisburg, PA 17101
(717) 728-2628
Attorney for Garnishee,
Graystone Tower Bank
Date: July 5, 2011
3
VERIFICATION
Kimberly Taylor deposes and says, subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities, that she is the Deposit Operations Manager of Graystone
Tower Bank, that she makes this verification by its authority and that the facts set forth in the
foregoing Answers to Interrogatories in Attachment are true and correct to the best of her
knowledge, information and belief.
Date: July 5, 2011
Nam : Kimber Taylor
4
CERTIFICATE OF SERVICE
I hereby certify that on July 5, 2011, a copy of the foregoing Answers to Interrogatories in
Attachment Addressed to Garnishee, Graystone Tower Bank, was served upon the persons and in
the manner listed below:
Service by U. S. first class mail as follows:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
John A. Snyder
McQuaide Blasko, Inc.
811 University Drive
State College, PA 16801
5
FILED-OFFICE
HE PROTMHOTAR
2511 NG 24 AM 10' 04
UMB AdN5YL?ANIIA TY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES,
No. 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
TYPE OF PLEADING:
PRAECIPE FOR SATISFACTION OF
JUDGMENT
TYPE OF CASE:
CIVIL
FILED ON BEHALF OF:
PLAINTIFF
COUNSEL OF RECORD FOR
FOR THIS PARTY:
John A. Snyder, Esquire
PA I.D. No. 66295
McQUAIDE BLASKO, INC.
811 University Drive
State College, PA 16801
Ph# (814) 238-4926
Fax#(814) 238-9624
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES, No. 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned case satisfied of record.
McQUAIDE BLASKO, INC.
Dated: August 23, 2011 By: (?? G.
Jo A. Snyder, Esquire
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
CERTIFICATE OF SATISFACTION
Judgment is hereby satisfied as against Defendant in the above-referenced matter.
D. )Buelf, Prothonotary
[SEAL]
Date: , 2011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ENTERPRISE MEDICAL
SERVICES, No 11-25
Plaintiff,
V.
CENTRAL PENNSYLVANIA
PULMONARY ASSOCIATES, LLC,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Plaintiff's Praecipe for Satisfaction
of Judgment in the above-captioned matter was served via First Class Mail, postage
prepaid, on this 23rd day of August, 2011, to the attorneys/parties of record:
Central Pennsylvania Pulmonary Associates, LLC
2250 Millennium Way, Suite 400
Enola, PA 17025
McQUAIDE BLASKO, INC.
By: G• 6?'7'
JJohif A. Snyder, Esquire
I.D. No. 66295
811 University Drive
State College, PA 16801
(814) 238-4926
Attorneys for Plaintiff
4
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-25 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ENTERPRISE MEDICAL SERVICES, Plaintiff (s)
From CENTRAL PENNSYLVANIA PULMONARY ASSOCIATES, LLC., 2250 MILLENNIUM
WAY, SUITE 400, ENOLA, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of GRAYSTONE BANK, 417 VILLAGE DRIVE, CARLISLE, PA 17015
GARNISHEE(S) as follows:
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 $7,709.00
Interest FROM 9/8/2010 - $693.81
Attv's Comm %
Arty Paid $56.00
Plaintiff Paid
Date: JUNE 13, 2011
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs - 4t 14f43. W
Q?-
DaiCi-d-Well, Prothon tary
By:
Deputy
REQUESTING PARTY:
Name JOHN A. SNYDER, ESQUIRE
Address: MCQUAIDE BLASKO, INC.
811 UNIVERSITY DRIVE
STATE COLLEGE, PA 16801
Attorney for: PLAINTIFF
Telephone: 814-238-4926
Supreme Court ID No. 16801
TRUE COPY FROM RECORD
In Testimony whereof, I here into sat my twW
and the I of laid C rt at Carlisle, P&
This lay of-, ,20
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Prothonotar
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Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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..;;JEFF
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CUNPEN1NSYI_Vu f4jjA,- i '
Enterprise Medical Services, Inc.
Case Number
vs.
Central Pennsylvania Pulmonary Associates, LLC 2011-25
SHERIFF'S RETURN OF SERVICE
06/16/2011 02:03 PM - Michael Barrick, Deputy, who being duly sworn according to law, attached as herein
commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands,
possession, or control of the within named garnishee, Graystone Bank, 417 Village Drive, South Middletor
Township, Carlisle, PA 17015, Cumberland County, by handing to JENEAN FINLEY- BANKING REP.,
personally 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 21, 2011 to Central Pennsylvania
Pulmonary Assoociates, LLC, 2250 Millennium Way, Ste 400, Enola, PA 17025.
01/24/2012 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: $89.48 SO ANSWERS,
y
January 24, 2012 RON R ANDERSON, SHERIFF
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