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Home My WebLink About11-90431'F4 i '7,; RITE AID HDQTRS. CORP. Plaintiff, V. GEROLYMATOS INC. Defendant. it ?tLi ??f?;^jlS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 11-9043 Civil PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter, Respectfully submitted, LATSHA DAVIS & McKENNA, P.C. C ? Dated: c1 By: S en M. Montresor Attorney I.D. No. 74244 Daniel R. Jameson Attorney I.D. No. 307543 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 (717) 620-2424 Attorneys for Plaintiff, Rite Aid Hdqtrs. Corp. 1. ) AOL l G SCI 1371980 ?a RITE AID HDQTRS. CORP. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA NO. 11-9043-Civil v. GEROLYMATOS INC. : CIVIL ACTION Defendant. AFFIDAVIT OF SERVICE The undersigned hereby verifies that he made service of the Civil Complaint upon Defendant, Gerolymatos Inc., via certified mail, return-receipt requested, as follows: Connecticut Secretary of State Registered Agent for Gerolymatos Inc. 30 Trinity Street PO Box 150470 Hartford, CT 06115-0470 This statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Dated: ?5 X? I By: 140664%1 ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: Connecticut Secretary of State Registered Agent for Gerolymatos Inc_ 30 Trinity Street PO Box 150470 Hartford, CT 06115-0470 A. Si . -, J'J X F`" r 0D /dent UP B. Re l b (Printed N M7 C. of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail Registered )( Return Receipt for Merchandise ? insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (rnvm*rfrom sarwoe kbeo 7 010 1670 0001 0908 6 611 PS Form 3811, February 2004 Domestic Return Receipt 102e9e.o2.M-1540 ARY 2013 APR -4 PH 1: 52 Andrew P. Dollman adollman @ldylaw.com Attorney ID #209466 Latsha Davis & McKenna, P.C. 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Attorneys for Plaintiff, Rite Aid Hdqtrs. Tele: (717) 620-2424; Fax: (717) 620-2444 Corp. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RITE AID HDQTRS. CORP. Plaintiff NO. 11-9043 Civil V. : GEROLYMATOS INC. CIVIL ACTION Defendant PRAECIPE FOR DEFAULT JUDGMENT,ASSESSMENT OF DAMAGES AND VERIFICATION OF ADDRESS AND NONMILITARY SERVICE TO THE PROTHONOTARY: Please enter judgment in favor of Plaintiff and against Defendant, Gerolymatos Inc., for want of an answer, and assess Plaintiff's damages in the amount of$583,617.10. Pursuant to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities, I verify that: 1. The precise last known address of Defendant, the address at which it indicated that it could be served to the Attorney General for the State of New York, is 1160 Fifth Avenue, Suite 106, New York, New York 10029. *I '56'Pj a � a8a(�90 12. 2. The annexed notice of intention to file praecipe was mailed to Defendant, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. Defendant is a corporation to which the Soldiers and Sailors Relief Act of 1940, as amended, does not apply. Respectfully submitted, LATSHA DAVIS & MCKENNA, P.C. Dated: ( 1311-3 B Y (?K� Andrew P. Dollman Attorney 1. D. No. 209466 1700 Bent Creek Blvd., Suite 140 Mechanicsburg, PA 17050 (717) 620-2424 Attorneys for Plaintiff, Rite Aid Hdqtrs. Corp. 2301500 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the foregoing Praecipe for Default Judgment, Assessment of Damages and Verification of Address and Nonmilitary Service has been served, via first class mail, postage pre-paid, upon the person(s) listed below: Gerolymatos Inc. 1160 Fifth Avenue, Suite 106 New York, NY 10029 Date: V1311_3 Andrew P. Dollman 2301500 Steven M. Montresor smontres(a-jldylaw.com Attorney ID #74244 Andrew P. Dollman adollman a>Idylaw.com Attorney ID #209466 Latsha Davis & McKenna, P.C. 1700 Bent Creek Boulevard, Suite 140 Mechanicsburg, PA 17050 Attorneys for Plaintiff, Tele: (717) 620-2424; Fax: (717) 620-2444 Rite Aid Hdqtrs. Corp. RITE., AID I-IDQTRS. CORP. IN THE COURT OF COMMON PLEAS Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 11-9043 GEROI,YMATOS INC. CIVIL, ACTION Defendant, DATE OF NOTICE: February 25, 201.3 IMPORTANT NOTICE TO: Gerolymatos, Inc. C/O Connecticut Secretary of State Registered Agent for Gerolymatos Inc. 1160 Fifth Avenue, Suite 106 New York, NY 10029 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 (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 RIGL-ITS. zi 9074 1 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Andrew P. Dollman 2 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the foregoing Notice of Default Judgment was served by first-class United States mail, postage prepaid, upon the following: Gerolymatos Inc. 1160 Fifth Avenue, Suite 106 New York, NY 10029 .-s Dated: Andrew P. Dollman 3 Office of Prothonotary of Court of Common Pleas of Cumberland County NOTICE OF ENTRY OF JUDGMENT, ORDER OR DECREE RITE AID HDQTRS. CORP. Plaintiff NO. 11-9043 V. GEROLYMATOS INC. CIVIL ACTION Defendant Pursuant to the requirements of Pennsylvania Rule of Civil Procedure 236, you are notified that there was entered in this office today in the above-captioned case judgment in favor of Plaintiff and against Defendant, Gerolymatos Inc. by Default for want of an answer and damages assessed at the sum of$583,617.10. Date: Prothonotary Mailed: To: Gerolymatos Inc. 1160 Fifth Avenue, Suite 106 New York, NY 10029 2301500