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Home My WebLink About11-5323i r FILEO-OFFICE R. J. MARZELLA & ASSOCIATES, P.C. OF THE PROTHONOTARY BY: Robin J. Marzella, Esquire 2011 JUN 28 PM 1 01 Pennsylvania Supreme Court I.D. No. 66856 3513 North Front Street AttornMGir'l ?y? COUNTY Harrisburg, PA 17110 Alfred , uall y Telephone: (717) 234-7828 and as Administrator, for the Facsimile: (717) 234-6883 Estate of Eva Girondi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Alfred Girondi, Jr., Individually and as Administrator, for the Estate of Eva Girondi, t V 't Plaintiff Docket No. Civil action (x)Law ( )Equity V. Internists of Central Pennsylvania, Ltd Jury Trial Demanded Defendants PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons to Defendants listed below: Internists of Central Pennsylvania, Ltd., 108 Lowthar Street, Lemoyne, Cumberland County, PA 17043 1 Writ of Summons shall be issued and forwarded to ( ) Agaruey (X) Sheriff Robin J. Marzella. Esquire 3513 North Front Street HarrisburE, PA 17110 (717) 234-7828 Names/Address/Telephone No. of Attorney of Supreme Co rt No. 66856 Date: (? Z$ uc. ?3 310 ( LAIC L or R. J. MARZELLA & ASSOCIATES, P.C. BY: Robin J. Marzella, Esquire Pennsylvania Supreme Court I.D. No. 66856 3513 North Front Street Attorneys for Harrisburg, PA 17110 Alfred Girondi, Jr., Individually Telephone: (717) 234-7828 and as Administrator, for the Facsimile: (717) 234-6883 Estate of Eva Girondi IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA Alfred Girondi, Jr., Individually and as Administrator, for the Estate of Eva Girondi, _ S3 a3 ?V Plaintiff Docket No. Civil action (x)Law ( )Equity V. Internists of Central Pennsylvania, Ltd. Jury Trial Demanded Defendants WRIT OF SUMMONS WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. ll Prothonotary Date: dg { b Deputy % )C - heck here if reverse is used for additional information SHERIFF'S OFFICE OF CUMBERLAND-COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy f IL-ED`UFF iCE 2011 JUL 12 AM 8: 4 4 Richard W Stewart Solicitor Orff . E r Tl fr RIFF CUMBERLAND COUNTY PENNSYLVANIA Alfred Girondi, Jr. vs. Internists of Central Pennsylvania Case Number 2011-5323 SHERIFF'S RETURN OF SERVICE 06/30/2011 03:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 30, 2011 at 1520 hours, he served a true copy of the within Writ of Summons, upon the within named defendant, to wit: Internists of Central Pennsylvania, by making known unto Heather Marlow, Receptionist for Internists of Central Pennsylvania at 108 Lowther Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $44.00 July 01, 2011 Q W ;C4- TIM B A , DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (C,' C0m'yS[A0 S^errtf. Te?eosoYt. Inc. r "h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Docket No. 11-5323 Administrator for the Estate of EVA GIRONDI, Deceased, CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION Plaintiff V. INTERNISTS OF CENTRAL PENNSYLVANIA, LTD., Defendants. JURY TRIAL DEMANDED c rn ?' .? rTs c? To the Prothonotary: C-) u , ENTRY OF APPEARANCE F C„'7? c' `- N co F.5 Kindly enter the appearance of Stevens & Lee, P.C., Michael D. Pipa, Esquire and Brandon R. Conrad, Esquire on behalf of Defendant Internists of Central Pennsylvania, Ltd., and serve all papers at 17 North Second Street, 16th Floor, Harrisburg, Pennsylvania, 17101. STEVENS & LEE Date: July 27, 2011 By: Michael D. Pipa, Esqui Attorney I.D. No. 53624 Brandon R. Conrad, Esquire Attorney I.D. No. 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (610) 371-7743 (facsimile) mdp@stevenslee.com brc@stevenslee.com Counsel for Defendant Internists of Central Pennsylvania, Ltd. S Ll 1088153v 1 /041199.00551 Ale` CERTIFICATE OF SERVICE I, Michael D. Pipa, Esquire, certify that on this date, I served a certified true and correct copy of the foregoing document upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: July 27, 2011 S L l 1088153v 1 /041199.00551 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Administrator for the Estate of EVA GIRONDI, Deceased, Plaintiff V. INTERNISTS OF CENTRAL PENNSYLVANIA, LTD_, Defendants. Docket No. 11-5323 CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO THE PROTHONOTARY: -u3 N C MW m X= r+? Co .?T _. j r -0 .. c ?a 5; x ni ,? Ys Please enter a Rule upon Plaintiff in the above-captioned matter to file a Complaint within twenty (20) days of the Rule or suffer a Judgment of non pros. STEVENS & LEE Date: February/ ?, 2012 By: ftp?_ Michael D. Pipa, Esquire Attorney I.D. No. 53624 Brandon R. Conrad, Esquire Attorney I.D. No. 308249 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (610) 371-7743 (facsimile) mdp a)stevenslee.com brc@stevenslee.com Counsel for Defendant Internists of Central PA, LTD. SL 1 1132 157v 1 041 199.00551 2 CERTIFICATE OF SERVICE I, Brandon R. Conrad, Esquire, certify that on this date, I served a certified true and correct copy of the foregoing Praecipe upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: February 4 2012 VV_ Brandon R. Conrad, Esquire SLI 1132157vI 041 199.00551 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Docket No. 11-5323 Administrator for the Estate of EVA GIRONDI, Deceased. CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION Plaintiff' x. INTERNISTS OF CENTRAL PENNSYLV 4NIA, LTD.. Defendants. JURY TRIAL, DEMANDED C rncO CO te 2 3117 r -- ca v -fc) ?= RULE TO FILE COMPLAINT CMA AND NOW, on this 1711 day of iLO?, a Rule has been entered upon Plaintiff to file a Complaint within twenty (20) days of the Rule or suffer a Judgment of non pros. 1 Prothonotary S1.1 1 132157v 1 041199.00551 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Administrator for the Estate of EVA GIRONDI, Deceased, Plaintiff V. INTERNISTS OF CENTRAL PENNSYLVANIA, LTD., Defendants. Docket No. 11-5323 if f1' - C CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION JURY TRIAL DEMANDED PRAECIPE FOR ENTRY OF JUDGMENT OF NONPROS TO THE PROTHONOTARY: Kindly enter judgment of non pros against Plaintiff, Alfred Girondi, Jr., Individually and as Administrator for the Estate of Eva Girondi, Deceased, and in favor of Defendant, Internists of Central Pennsylvania, Ltd., in the above-captioned matter. Pursuant to Pa. R.C.P. 237.1, the undersigned certifies that written notice of the intention to file this Praecipe was mailed to the parties against whom judgment is to be entered after Plaintiff's failure to file a Complaint within twenty (20) days pursuant to a Rule to File Complaint and at least ten (10) days prior to the date of the filing of this Praecipe. See Rule to File Complaint, dated February 17, 2012, attached hereto as Exhibit A, and Notice of Intent to File Praecipe for Judgment of Non Pros dated April 4, 2012, attached hereto as Exhibit B. By e-mail correspondence, Defendants provided a 5-day extension to file a Complaint on April 13, 2012, which provided an extension until Wednesday, April 17, 2012. See e-mail correspondence, attached hereto as Exhibit C. SL I 1156995 v 1 041199.00551 Cj?.W ?Uh? c o uo'? LJ STEVENS & LEE Date: May 2012 By: Michael D. Pipa, Esquire Attorney I.D. No. 53624 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (phone) (610) 371-7743 (fax) mdp@stevenslee.com Counsel for Defendant SL I 1156995v l 041199.00551 Exhibit A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Docket No. 11-5323 Administrator for the Estate of EVA GIRONDI, Deceased. CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION Plaintiff INTERNISTS OF CENTRAL PENNSYLVANIA. LTD.. Defendants. JURY TRIAL, DEMANDED C7 C C .?D v of t 3 D? N q rn RULE TO FILE COMPLAINT oia AND NOW, on this _ day of _ __ .y? a 241+, a Rule has been entered _74k , upon Plaintiff to file a Complaint within twenty (20) days of the Rule or suffer a Judgment of nom pros. C?„^ Prothonotary SL 1 1132 1 i7v 1 041 199.00551 Exhibit B STEVENS & LEE LAWYERS & CONSULTANTS 51 South Duke Street Lancaster, PA 17602 (717) 291-1031 Fax (717) 394-7726 www.stevenslee.com Direct Dial: (717) 399-6645 Email: brc@stevenslee.com Direct Fax: (610) 371-8505 April 4, 2012 Robin Marzella R.J. Marzella & Associates, P.C. 3 513 North Front Street Harrisburg, PA 17110 Re: Girondi v. Harty, et al. Dear Ms. Marzella: Enclosed please find Notices in the Girondi v. Harty and Girondi v. Internist of Central Pennsylvania matters. Very truly yours, STEVENS & LEE Brandon R. Conrad BRC:paha Enclosures Philadelphia • Reading • Valley Forge • Lehigh Valley Harrisburg Lancaster • Scranton Wilkes-Barre Princeton Cherry Hill New York Wilmington A PROFESSIONAL CORPORATION SL I 1 147235v 1 041199.00551 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALFRED GIRONDI, JR., Individually and as Administrator for the Estate of EVA GIRONDI, Deceased, Docket No. 11-5323 CIVIL ACTION - MEDICAL PROFESSIONAL LIABILITY ACTION Plaintiff V. JURY TRIAL DEMANDED INTERNISTS OF CENTRAL PENNSYLVANIA, LTD., Defendants. NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT OF NON-PROS TO: Alfred Girondi, Jr., Individually and as Administrator for the Estate of Eva Girondi, c/o Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Date: April 4, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT IN THIS CASE. 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 RIGHT TO SUE THE DEFENDANTS AND THEREBY LOSE 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 INFORMATION ABOUT HIRING A 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. 04/04/2012 SL1 1147237vl 041199.00551 Date: April q , 2012 04/04/2012 SL1 1147237v1 041199.00551-- By: Michael D. Pipa, Esquire Attorney I.D. No. 53624 Brandon R. Conrad, Esquire Attorney I.D. No. 308249 17 North Second Street, 16th Floor Harrisburg, PA 17101 (717) 255-7376 (610) 371-7743 (facsimile) mdp@stevenslee.com brc@stevenslee.com Counsel for Defendant Internists of Central PA, LTD. 2 CERTIFICATE OF SERVICE I, Brandon R. Conrad, Esquire, certify that on this date, I served a certified true and correct copy of the foregoing Notice of Intent to File a Praecipe for Entry of Non Pros upon the following counsel of record, by depositing the same in the United States mail, postage prepaid, addressed as follows: Robin J. Marzella, Esquire R.J. Marzella & Associates, P.C. 3513 North Front Street Harrisburg, PA 17110 Counsel for Plaintiff Date: April , 2012 Brandon R. Conrad, Esquire - 04/04/2012 SL1 1147237v1 041199.00551 Exhibit C Conrad, Brandon R. From: Conrad, Brandon R. Sent: Wednesday, April 11, 2012 5:09 PM To: Jacqulyn Harris Cc: Robin Marzella (RMarzella@rjmarzella.com) Subject: RE: Girdondi v. Harty Complaint Extension We will grant this extension until Wednesday, April 18. 1 look forward to reviewing the Complaint. From: Jacqulyn Harris [mailtoJharris rjmarzella.com1 Sent: Wednesday, April 11, 2012 4:49 PM To: Conrad, Brandon R. Subject: Girdondi v. Harty Complaint Extension Attorney Conrad, The Complaint deadline in this matter is Friday, April 13, 2012. Attorney Marzella's husband is having surgery and she is requesting an extension of the Complaint until Wednesday April 18, 2012. We will be dismissing the claims as to Dr. Kapoor and Internists of Central Pennsyslvania. Should you have any questions, please feel free to contact me. Thank you, Jackie Ja,cqu.L R. }f arrck Law Clerk to Robin J. Marzella, Esq. R.J. Marzella & Associates, P.G. 3513 North Front Street Harrisburg, PA 17110 717.234.7828 1