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HomeMy WebLinkAbout13-3626 12194911 LANCE J. NELSON, ESQUIRE UtN�YS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 k'S i r4t. I LEO M. GIBBONS, ESQUIRE N13 ? k ATTORNEY I.D. NO. 67267 COPB�Y AT ORNEY QUIRE I.D. D. NO. 06844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381 -0660 (610) 436 -0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 CUMBERLAND COUNTY, PENNA. Plaintiff V. CIVIL ACTION - LAW 3�(� ✓ GREGORY A. NELSON NO. 13 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 Defendant PRAECIPE TO THE PROTHONOTARY: Pursuant to Pennsylvania Rule of Civil Procedure 3002, enter judgment against the above - captioned defendant in the amount of $373,627.77 in accordance with the attached certified copy of the docket entries which certifies that judgment was entered in this amount in the Court of Common Pleas of Chester County, Pennsylvania at docket no. 13 -01502 on February 20, 2013 and index said judgment against the defendant. MacELREE HARVEY, LTD. By: Lance J. Nelson, Esq Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff *, o a tvo� �rn cu led CASE 1VIARY REPORT 2013-01502-JD NELSON, GAIL A VS. NELSON, GREGORY .A. Case Type: JUDGMENT FOREIGN JUDGMENT THIS JUDGMENT Case Initiation Date: 02/20/2013 Not Active Since: 03/ 9/20 1.3 .2 CERTIFIED Case Status: NO ACT FEND -456 IN FAVOR OF GAIL A. NELSON Arbitration Date: Arbitration Time: ANT) AGAINST GREGORY A. NELSON Trial Ready Date: No Related Cases IN THE AMOUNT OF 02/20/2013 1:53 PM $373,627.77 CERTIFICATION OF $ 373,627.77 Terms: (INDEXED ON 32013)ARREAGES CERTIFIED 02/20/2013 01:53 PM ACTIVE FROM THE RECORD Judgment Against: NELSON, GREGORY A 1 � � A Judgment For: NELSON, GAIL A a w —.&brw Deputy Prothonotary April 1, 206 JU DGE ROBERT J. SHENKIN 02/20/2013 Plaintiff- GAIL A. NELSON Party Start/End Dates: 02/20/2013 vs. Defendant: GREGORY A NELSON Party Start/End Dates: 02/20/2013 Date Docket Information CV-CaseSumExemp.jj)t Page 1 of 2 Printed: 04/01/2013 09:04 2013- 0 f502 -JD NELSON, GAIL A VS. NELSON, GREGORY A Date Docket Information 02/20/2013 JUDGMENT STATUS DOCKET. CERTIFICATION OF ARREAGES Amount: 373,627.77 Pre - CERTIFICATION OF ARREAGES Interest: 0.00 Attorney Fees: 0.00 Court Costs: 0.00 Other Fees: 0.00 CERTIFICATION OF ARREAGES Total: 373,627.77 Total Accrued Costs: 0.00 Total Accrued Interest: 0.00 Tenns: {INDEXED ON 32013} Type: CERTIFICATION OF ARREAGES Judge: NO JUDGE ASSIGNED CERTIFICATION OF ARREAGES Date: 02/20/2013 CERTIFICATION OF ARREAGES Time: 1:53PM Referee: Recommendation .Date: CERTIFICATION OF ARREAGES Status: ACTIVE CERTIFICATION OF ARREAGES Status Date: 02/20/2013 CERTIFICATION OF ARREAGES Status Time: 1:53PM. CERTIFIC:'ATION OF ARREAGES For: NELSON, GAIL A - Plaintiff CERTIFICATION OF .ARREAGES Against: NELSON, GREGORY A - Defendant 02/20. %2013 CERTIFICATION OF 236 NOTICE 02/20/2013 JUDGMENT 03/26/2013 WRIT FEE Receipt: 639132 Date: 03/26/2013 03/27/2013 EXEMPLIFICATION OF JUDGMENT - PA FEE Receipt: 6391.75 Date: 03/2 V.2 0 13 03/27/2013 EXEMPLIFICATION OF JUDGMENT - PA FEE Receipt: 639175 Date: 03/27/2013 03/27/2013 EXEMPLIFICATION OF JUDGMENT - PA FEE Receipt: 639175 Date: 03/27/2013 03/29/2013 .JUDGMENT OPEN / STRIKE FEE Receipt: 639466 Date: 03129/2013 CV- CaseSumExemp.rpt Page 2 of 2 Printed: 04/01/2013 09:04 IN T`I-iE COURT OF COMMON PLEASE GAIL. A. NELSON `a PLAINTIFF CHESTER COUNTY, PENNS°YLANIA DOMES RELATIONS OFFICE q�, v s. r, DR DOCKET NUMBER: 00674N2007 t: GREGORY A. NELSON CASE NUMBER: 91 1109128 DEFENDANT { JUDGMENT NUMBER: 13 9 � 0 JUDGMENT " TO THE PROTHONOTARY: Tn Q PLEASE ENTER A JUDGMENT IN FACTOR OF GAIL A. NELSON, (PLAINTIFF) v. GREGORY A. NELSON (DEFENDANT) IN THE AMOUNT OF THREE - HUNDRED SEVENTY -THREE THOUSAND SIX HUNDRED TW'EN'TY -SEVEN THOUSAND DOLLARS AND SEVENTY - SEVEN CENTS ($373,627.77} AS SET FORTH IN T14E CERTIFICATION OF ARREARAGES OF THE CHESTER COUNTY DOMESTIC RELATIONS OFFICE ,ATTACHED HERETO. l 1 Date: DOMESTIC RELATIONS STAFF ATTORNEY y9 . �l0 CERTIFIED FROM, THE REQOR ATTES ' DEPUTY PROTHONOTARY I t ' In the Court of Common Pleas of CHESTER County, Pennsylvania IL DOMESTIC RELATIONS SECTION l x _ CHESTER CO JUSTICE CENTER, 201 W MARKET STREET, PO BOX 2748, WEST CHESTER, PA: 193@i0 }' Phone: (610) 344 - -6215 FEBRUARY 20, 2013 Fax: (610) 344 -6977 Plaintiff Name: GAIL A. NELSON n' Defendant Name: GREGORY A. NELSON '''�r��n Docket Number: 00674N2007� PACSES Case Number: 911109128 ' Cit- Other State ID Number: Please note: All correspondence must include the PACSES Case Number. Certification of Arrearaae I, SAMANTHA MCCABE, hereby certify that arrearages on the above case as of tit FEBRUARY 20, 2013 total $873,627.77. Date Signature Form EN -003 Service Type M Worker I i`15236' 12194911 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381 -0660 (610) 436 -0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 :. CUMBERLAND COUNTY, PENNA. Plaintiff V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 Defendant CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe have been served upon the following persons, by the following means and on the date(s) stated: Name Means of Service Date of Service Sheryl R. Rentz, Esquire First Class Mail June Z�a 2013 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 Gregory A. Nelson First Class Mail June 2-P 2013 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff k 1219320_1 C,uMBERLAND CDUN" �E��P�SYLV��lA LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381 -0660 (610) 436 -0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 CUMBERLAND COUNTY, PENNA. Plaintiff V CIVIL ACTION - LAW GREGORY A. NELSON NO. 1 e2 1 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 Defendant And HIGHMARK MEDICARE SERVICES,INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17089 -0426 Garnishees 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 Gregory A. Nelson, defendant; and © 3. against Highmark Medicare Services, Inc. and Highmark, Inc.,'garnishees; Ca 4. and index this writ SO , Q 32•. �`� • `( 6.50 v 1219320_1 a. against Gregory A. Nelson, defendant; and b. against Highmark Medicare Services, Inc. and Highmark, Inc., garnishees; as a lis pendens against real property of the defendant in name of garnishees as follows: All money and /or other property in your possession care custody and /or c ontrol that belong to de fendant Gregory A Nelson that you owe to defendant Gregory A. Ne lson and /or defendant, Gregory A Nelson has any interest. 5. Amount due $ 373,627.77 Interest from 2/21/2012 $ Costs to be added $ MacELREE HARVEY, LTD. By: Lfly I I � J ", � Lance J. Nelson, Esqulire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 1.3 -3626 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GAIL A. NELSON Plaintiff (s) From GREGORY A. NELSON, 1401 WALNUT STREET, APT. 301, PHILADELPHIA, PA 19102 (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 GARNISHEE(S) as follows: - HIGHMARK MEDICARE SERVICES, INC., 1800 CENTER STREET, CAMP HILL, PA 17101 HIGHMARK, INC., 1800 CENTER STREET, CAMP HILL, PA 17089 - ALL MONEY AND /OR OTHER PROPERTY IN YOUR POSSESSION, CARE AND /OR CONTROL THAT BELONGS TO DEFENDANT, GREGORY A. NELSON, THAT YOU OWE TO DEFENDANT, GREGORY A. NELSON AND /OR DEFENDANT, GREGORY A. NELSON, HAS ANY INTEREST- 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, in the possession of If property than the an a named g not levied ishee, y ou are directed to notify him/her t that he /she has been added as a of If other th nam garnishee, garnishee and is enjoined as above stated. Amount Due $373,627.77 Plaintiff Paid $ Interest FROM 2/21/2012 Attorney's Comm. % Law Library $.50 Attorney Paid $62.50 Due Prothonotary $2.25 Other Costs $ Date: JUNE 21, 2013 David D. Buell, Prothonotary By: Deputy REQUESTING PARTY: Name: z6 M. G) 6bam j ESQUIRE Address: MACELREE HARVEY LTD. 17 W. MINER STREET P.O. BOX 660 WEST CHESTER, PA 19381 -0660 Attorney for: PLAINTIFF Telephone: 610- 436 -0100 Supreme Court ID No. 61;L47 C —0F F ICr_ 12375301 ,- T I'E P ROTHI_NOTAIt`E 2813 JUL 16 Ate 6: CUMBERLAND COUNTY PENNSYLVANIA LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON - IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 CUMBERLAND COUNTY, PENNA. Plaintiff V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 2013-03626 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 Defendant And NOVITAS SOLUTIONS 1800 Center Street Camp Hill, PA 17089 Garnishee 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 Gregory A. Nelson, defendant; and 3. against Novitas Solutions, garnishee; 4. and index this writ Oa. against Gregory A. Nelson, defendant; and �aq °a�a Qty b. against Novitas Solutions, garnishees; '%a.aS--bLq 0 . oci .°c> e" 933 y� 0-* aq3 �� 1237530_1 as a lis pendens against real property of the defendant in name of garnishees as follows: All money and/or other property in your possession care custody and/or control that belongs to defendant Gregory A Nelson that you owe to defendant Gregory A. Nelson and/or defendant, Gregory A. Nelson, has any interest. 5. Amount due $ 373,627.77 Interest from 2/21/2012 $ Costs to be added $ MacELREE °HARVEY, LTD. By: ' �l Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-3626 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GAIL A. NELSON Plaintiff(s) From GREGORY A.NELSON, 1401 WALNUT STREET,APT.301,PHILADELPHIA,PA 19102 (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 GARNISHEE(S)as follows: NOVITAS SOLUTIONS, 1.800 CENTER STREET,CAMP HILL,PA 17089,ALL MONEY AND/OR OTHER PROPERTY IN YOUR POSSESSION,CARE,CUSTODY AND/OR CONTROL THAT BELONGS TO DEFENDANT,GREGORY A.NELSON,THAT YOU OWE TO DEFENDANT,GREGORY A.NELSON AND/OR DEFENDANT,GREGORY A.NELSON HAS ANY INTEREST 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$373,627.77 Plaintiff Paid$ Interest FROM 2/21/201.2 Attorney's Comm. % Law Library$ Attorney Paid$91.50 Due Prothonotary$2.25 Other Costs$ Date: 7/16/13 11,Protho Lary {;call By: Deputy REQUESTING PARTY: Name : LANCE J.NELSON,ESQUIRE Address:MACELREE HARVEY,LTD. 17 W.MINER STREET P.O.BOX 660 WEST CHESTER,PA 19381 Attorney for: PLAINTIFF Telephone: 610-436-0100 Supreme Court ID No.61059 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff " Phi 0 N 0 �k wti o, wrt Rruhli"f� Jody S Smith Chief Deputy C0� 2� �, �0.* 29 Richard W Stewart '�1MBERLAND G���,NTY Solicitor f;PP=``'FT Ec4HERI~- PENNSYLVANIA Gail A Nelson Case Number vs. Gregory A Nelson 2013-3626 SHERIFF'S RETURN OF SERVICE 07/24/2013 01:17 PM -Amanda Cobaugh, Deputy Sheriff,who being duly sworn according to law, states that on July 24, 2013 at 1317 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Novitas Solutions, 2020 Technology Parkway, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Karen Ryan, Executive Assistant 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 July 25, 2013 to Gregory A. Nelson, 1401 Walnut Street, Apt. 301, Philadelphia, PA 19102. NOTE: Novitas Solutions has moved from 1800 Center Street, Camp Hill, PA 17011 to the address where service was made at 2020 Technology Parkway, Mechanicsburg, PA 17050. There is no one associated with Novitas Solutions at 1800 Center Street that can accept service of civil papers. C ABAUGH, DEPU SO ANSWERS, July 25, 2013 RbNO R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosoft,Inc. '1253707_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PL.AI TIFF ATTORNEY I.D. NO. 61059 MQD � :°r= LEO M. GIBBONS, ESQUIRE c71 -0r—i ATTORNEY I.D. NO. 67267 �= KRISTIN A. MOLAVOQUE, ESQUIREQ ATTORNEY I.D. NO. 306844 - MacELREE HARVEY, LTD. ° 17 W. Miner Street Cr, ,w P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 2013-03626 Defendant And NOVITAS SOLUTIONS Garnishee PRAECIPE TO RELEASE GARNISHMENT TO THE PROTHONOTARY: Please release the garnishment against Novitas Solutions, garnishee, in the above-captioned action. MacELREE HARVEY, LTD. 2. By: /A Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff �g. wilo 01 V*a941 b9 1253707_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 2013-03626 Defendant And NOVITAS SOLUTIONS Garnishee CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe to Release Garnishment has been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Novitas Solutions First Class Mail Augusts , 2013 2020 Technology Parkway Mechanicsburg, PA 17050 Noreen O'Grady, Esquire First Class Mail August 5 , 2013 Office of General Counsel, Region III Center for Medicare & Medicaid Svcs. The Public Ledger Building, Ste. 418 150 S. Independence Mall West Philadelphia, PA 19106-3499 Sheryl R. Rentz, Esquire First Class Mail August , 2013 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 -1253707_1 Gregory A. Nelson First Class Mail August , 2013 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE HARVEY, LTD. By. /t) Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff SHERIFF'S 0FFICE OF CUMBERLAND COUNTY Ronny R Anderson m Sheriff p _0_0:X L� 13. M/�1 '."'"' + t i-' Jody S Smith M -r� Chief Deputy `_,_;* cn co Richard W Stewart '°' r SOiICttOr ICE A:Tr; Cr C C Gail A Nelson Case dumber vs. - Gregory A Nelson 2013-3626 SHERIFFS RETURN OF SERVICE .07103/2013 01:59 PM-Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 3, 2013 at 1359 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Highmark Inc., 1800 Center Street, Camp Hill, Cumberland County, Pennsylvania, 17011 by handing to Robin Walker, Executive Administrative Assistant, 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. 07/03/2013 01:59 PM-Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Highmark Medicare Services, Inc., but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Garnishment as "Not Served"at 1800 Center Street, East Pennsboro Township, Camp Hill, PA 17011. 07/03/2013 02:46 PM-Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 3, 2013 at 1440 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Highmark Medicare Services, Inc., NOW KNOWN AS Novitas Solutions, 2020 Technology Parkway, mechanicsburg, Cumberland County, Pennsylvania, 17055 by handing;to Lisa Wolff, Legal Counsel, 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 July 8, 2013 to Gregory A. Nelson at 1401 Walnut Street,Apt. 301, Philadelphia,. PA 19102(envelope provided by atty's office). SO ANSWERS, July 08, 2013 RONN�'R ANDERSON, SHERIFF ;c7 Countysuits Sinew,i eieosort Inc. i• 12537181 T - LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ' ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. >C_') 17 W. Miner Street ° �v P.O. Box 660 V, 1 West Chester, PA 1081-0660 ` (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 2013-03626 Defendant And HIGHMARK MEDICARE SERVICES,INC. And HIGHMARK, INC. Garnishees PRAECIPE TO RELEASE GARNISHMENT TO THE PROTHONOTARY: Please release the garnishment against Highmark Medicare Services, Inc., garnishee, in the above-captioned action. MacELREE HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff OVA 1253718_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW GREGORY A. NELSON NO. 2013-03626 Defendant And HIGHMARK MEDICARE SERVICES,INC. And HIGHMARK, INC. Garnishees CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe to Release Garnishment has been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Highmark Medicare Services, Inc. First Class Mail August 2013 1800 Center Street Camp Hill, PA 17101 Noreen O'Grady, Esquire First Class Mail August , 2013 Office of General Counsel, Region III Center for Medicare & Medicaid Svcs. The Public Ledger Building, Ste. 418 150 S. Independence Mall West Philadelphia, PA 19106-3499 Sheryl R. Rentz, Esquire First Class Mail August,, 2013 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 1253718_1 Gregory A. Nelson First Class Mail August , 2013 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE-HARVEY, LTD. By: vW YK Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 1255155_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff NO. 2013-03626 vs. GREGORY A. NELSON'- 1401 Walnut Street Philadelphia, PA 19102 ' Defendant Z�r� ,�; and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 . HIGHMARK, INC. 1' 1800 Center Street Camp Hill, PA 17101 Garnishees PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE, HIGHMARK, INC. Pursuant to Pennsylvania Rules of Civil Procedure 3146(b) enter judgment in favor of plaintiff, Gail A. Nelson and against garnishee, Highmark, Inc. in the amount of$758.16 consistent with garnishee's Answers to Interrogatories Nos. 1 and 2(a), a copy of which is attached hereto. MacELREE HARVEY LTD. By. �/p —W ' 9 Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff �� JUL. 30. 2013 1 : 19PM HIGHMARK LAW DEPT 412 5447423 No. 231 P. 2 12193401 i — a i LANGE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I-D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 i West Chester, PA 19381-0660 (610)436-0100 i GAIL A_ NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff V. CIVIL ACTION - LAW GREGORY A. NELSON ; NO. i 1401 Walnut Street, Apt. 301 ;I Philadelphia, PA 19102 Defendant And : HIGHMARK MEDICARE SERVICES,INC. E 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17089-0426 : Gamishees INTERROGATORIES TO GARNISHEE TO: Highmark, Inc. 1800 Center Street Camp Hill, PA 17089-0426 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: I 1. 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 the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? i i JUL. 30. 2013 1 : 19PM HIGHMARK LAW DEPT 412 5447423 N0, 231 P. 3 1219340_1 i I i 2. If the answer to Paragraph 1 is in the affirmative in any respect, please state: i, (a) How much you currently owe the defendant; (b) How much you are liable to the defendant on any negotiable or ;i other written instrument; I t-kN�K 15 ViJ(-J L Mt LC 7D �� � (c) How much the defendant claims that you owe the defendant or are liable to the defendant for? n 3. At the time you were served or at any subsequent time was there in your possession, custody, or control or in the joint possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? I, 4. If the answer to Paragraph 3 is in the affirmative, please identify any and all such property and whether it was in your possession, custody, control, or in your joint possession, custody, or control? 1 I hJ JUL- 30- 2013 1 : 19PM HIGHMARK LAW DEPT 412 5441423 N0. 231 P. 4 1219340_1 i i 5. 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 defendant held or claimed any interest? t�04 6. If the-answer to Paragraph 5 is in the affirmative, please identify said property and state its monetary value? i i 7. At the time you were served or at any subsequent time, did you hold as fiduciary 1 any property in which the defendant had an interest? 8. If the answer to Paragraph 7 is in the affirmative, please identify said property and state its monetary value. h 'l tv i� 9. 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 direction or consent and, if so, what was the consideration therefor and what was the property? I' 10. 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? Vy , JUL. 30. 2013 1 : 19PM HIGHMARK LAW DEPT 412 5447423 N0. 231 P. 5 12193401 i I 11. If the answer to Paragraph 10 is in the affirmative, please state in detail the nature of said transaction. I 4 I 12. At any time after you were served, did you hold legal title to property of the defendant, whether or not in fraud of creditors? n ( /0 I 13. If the answer to Paragraph 12 is in the affirmative, please identify in detail all such property. i I 14. At any time after you were served, did you own or possess real property subject to a mortgage, judgment or other lien in which the defendant had an interest? i i 15. f the answer to Par graph 14 is in the affirmative, please identify all such properties in detail. J i I i JUL- 30. 2013 1 : 19PM HIGHMARK LAW DEPT 412 5447423 N0. 231 P. 6 1219340_1 I i 16. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 17. If you are a bank or other financial institution, at the time you were served or at i any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. i i i MacELREE HARVEY, LTD. I Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 7Q i i 1255155_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff NO. 2013-03626 vs. GREGORY A. NELSON 1401 Walnut Street Philadelphia, PA 19102 Defendant and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17101 Garnishees CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe for Entry of Judgment have been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Cecelia Rene Halligan Facsimile 412-544-7423 August�, 2013 120 Fifth Avenue, Ste. 2180 and First Class Mail Pittsburgh, PA 15222 Sheryl R. Rentz, Esquire First Class Mail August , 2013 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 1255155_1 Gregory A. Nelson First Class Mail August , 2013 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE HARVEY, LTD. By. �& Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 1277863 1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 b:=' en LEO M. GIBBONS, ESQUIRE C: ATTORNEY I.D. NO. 67267 -c- -� KRISTIN A. MOLAVOQUE, ESQUIRE ,",.; ATTORNEY I.D. NO. 306844 vi �'a :=, MacELREE HARVEY, LTD. _-n 17 W. Miner Street P.O. Box 660 ('3�} West Chester, PA 19381-0660 _.xr (610) 436-0100 —4 c.� ..- GAIL A. NELSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. vs. : NO. 2013-03626 GREGORY A. NELSON Defendant and HIGHMARK MEDICARE SERVICES, INC. and : HIGHMARK, INC. Garnishees PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against the Garnishee, Highmark, Inc., in the above matter, satisfied upon payment of your costs only. MacELREE HARVEY, LTD. Date: 1 i `� By: qW9Y1A ,r Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 050 PD ATI-1 6 944(D6 R1'01410643 4 1277863_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. vs. : NO. 2013-03626 GREGORY A. NELSON Defendant and HIGHMARK MEDICARE SERVICES, INC. and : HIGHMARK, INC. Garnishees CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe to Satisfy Judgment Against Garnishee, Highmark, Inc. have been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Cecelia Rene Halligan First Class Mail September27 2013 120 Fifth Avenue, Ste. 2180 Pittsburgh, PA 15222 Sheryl R. Rentz, Esquire First Class Mail September 272013 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 Gregory A. Nelson First Class Mail September 2-32013 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE HARVEY, LTD. By: . clAtr--1/%---, Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 1219340 1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road `- .. Coatesville, PA 19320 CUMBERLAND COUNTY, PENNA. Plaintiff' � r V. CIVIL ACTION - LAW -V a Fri GREGORY A. NELSON NO. 13- Alva CvY. r 1401 Walnut Street, Apt. 301 ca C) Philadelphia, PA 19102 < Defendant " And c ca HIGHMARK MEDICARE SERVICES,INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17089-0426 Garnishees I TERROGATORIES TO GARNISHEE TO: Highmark, Inc. 1800 Center Street Camp Hill, PA 17089-0426 You are required to file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in judgment against you: 1. 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 the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? ` ' 1219340_1 2. If the answer to Paragraph 1 is in the affirmative in any respect, please state: (a) How much you currently owe the defendant; b) How much you are liable to the defendant on any negotiable or other written,instrument ; �.M LC T j (c) How much the defendant claims that you owe the defendant or are liable to the defendant for? � f 1 3. At the time you were served or at any subsequent time was there in your possession, custody, or control or in the joint possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? I 4. If the answer to Paragraph 3 is in the affirmative, please identify any and all such property and whether it was in your possession, custody, control, or in your joint possession, custody, or control? i I I i 12193401 5. 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 defendant held or claimed any interest? ( y s I 6. If the answer to Paragraph 5 is in the affirmative, please identify said property and state its monetary value? j I 7. At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the defendant had an interest? 8. If the answer to Para raph 7 is in the affirmative, please identify said property and state its monetary value. I i 1 t 'I 9. 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 direction or consent and, if so, what was the consideration therefor and what was the property? i t i E 10. 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? f 12193401 11: If the answer to Paragraph 10 is in the affirmative, please state in detail the nature of said transaction. 12. At any time after you were served, did you hold legal title to property of the defendant, whether or not in fraud of creditors? 1 13. If the answer to Paragraph 12 is in the affirmative, please identify in detail all such property. l i 14. At any time after you were served, did you own or possess real property subject to a mortgage,judgment or other lien in which the defendant had an interest? j 1 � 0 15. f the answer to Par graph 14 is in the affirmative, please identify all such properties in detail. i 1219340_1 16. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. t 17. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. ICJ 1 i MacELREE HARVEY, LTD. I By: 1, tn Lance J. Nelson, Esquire 1 Leo M. Gibbons, Esquire Kristin A, Molavoque, Esquire Attorneys for Plaintiff 3 L, cep 3 A 1385715_1 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF `- ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 tz MacELREE HARVEY, LTD. =`o = 17 W. Miner Street cr_i �? P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff NO. 2013-03626 vs. GREGORY A. NELSON 1401 Walnut Street Philadelphia, PA 19102 Defendant and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17101 Garnishees PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE, HIGHMARK, INC. Pursuant to Pennsylvania Rules of Civil Procedure 3146(b) enter judgment in favor of plaintiff, Gail A. Nelson and against garnishee, Highmark, Inc. in the amount of$2,215.36 consistent with garnishee's Amended Answers to Interrogatories Nos. 1 and 2(a), a copy of which is attached hereto. Undersigned counsel was informed by Highmark, Inc. that the original Amended Answers to Interrogatories have already been filed by Highmark, Inc. with the Cumberland County Prothonotary. MacELREE HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff C�o c (2 C) � k2l*- %19 ^'N -� r-�)c\tje� • FEB. 7. 2014 10: 21AM HIGHMARK LAW DEPT 412 5447423 N0, 034 P. 2 12193401 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D- NO. 67267 KRISTIN A. MOCAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19361-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 CUMBERLAND COUNTY, PENNA. Plaintiff V. CIVIL ACTION - LAW GREGORY A, NELSON NO, 1401 Walnut Street,Apt. 301 Philadelphia, PA 19102 Defendant And HIGHMARK MEDICARE SERVICES,INC, ; 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street ; Camp Hill, PA 17089-0426 Garnishees ItVTERROGATORIES T_O_GARNISHEE TO: Highmark, Inc, 1800 Center Street Camp Hill, PA 17089-0426 You are required to file answers to the following interrogatories within twenty(20)days after service upon you. Failure to do so may result in judgment against you: 1, 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 the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? S FEB. 7. 2014 10: 22AM HIGHMARK LAW DEFT 412 5447423 N0. 034 F. 3 12193401 2. If the answer to Paragraph 1 is in the affirmative in any respect, please state: ? (a) How much you currently owe the defendant; (b) How much you are liable to the defendant on any negotiable or other written instrument; 4 l !,R-q Ai,K (A-; LC Ti9 D (c) How much the defendant clalms that you owe the defendant or are liable to the defendant for? �JI 3. At the time you were served or at any subsequent time was there in your possession, custody, or control or in the joint possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or In part by the defendant? NO- 4, If the answer to Paragraph 3 is in the affirmative, please identify any and all such property and whether it was in your possession, custody, control, or In your joint possession, custody, or control? ] j FEB. 7. 2014 10: 22AM HIGHMARK LAW DEPT 412 5447423 N0. 0'34 P. 4 1219340_1 5, 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 defendant held or claimed any interest? 001 �5. If the answer to Paragraph 5 is in the affirmative, please identify said property and state its monetary value? N lIA , 7. At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the defendant had an interest? a. If the answerto Paragraph 7 is in the affirmative, please identify said property and state its monetary value. I i 1 9. 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 direction or consent and, if so, what was the consideration therefor and what was the property? f i� I 10. 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? � I I s FEB. 7. 2014 10: 22AM HIGHMARK LAW DEFT 412 5447423 N0, 034 F. 5 12i93ao 1 11. If the answer to Paragraph IQ is in the affirmative, please state in detail the nature of said transaction. 12. At any tune after you were served, did you hold legal title to property of the i defendant, whether or not in fraud of creditors? ,( + 13. If the answer to Paragraph 12 is in the affirmative, please identify in detail all such property. i 14. At any time after you were served, did you own or possess real property subject to a mortgage,judgment or other lien In which the defendant had an interest's t 0 15. f the answer to Pa graph 14 is in the affirmative please identify all such properties in detail. I G FEB. 7. 2014 10: 22AM HIGHMARK LAW DEFT 412. 5447423' N0, 034 F. 6 121930_1 1 E. if you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account In which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption,the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. /1-( P, 17. If you are a bank or other financial Institution,at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds 0 deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §8123? If so, identify each account. MacPLRI:E HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M, Gibbons, Esquire Kristin A. Molavoque. Esquire Attorneys for Plaintiff c . ' 13857151 LANCE J. NELSON, ESQUIRE ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff NO. 2013-03626 vs. GREGORY A. NELSON 1401 Walnut Street Philadelphia, PA 19102 Defendant and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17101 Garnishees CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe for Entry of Judgment have been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Cecelia Rene Halligan Facsimile 412-544-7423 February Z d, 2014 120 Fifth Avenue, Ste. 2180 and First Class Mail Pittsburgh, PA 15222 Sheryl R. Rentz, Esquire First Class Mail February a , 2014 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 13857151 Gregory A. Nelson First Class Mail February 2014 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 MacELREE HARVEY, LTD. By:1 Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson • Sheriff ( of �`.m f),eft i� "[tO „i, l ;'� . Jody S Smith Chief Deputy p : c, Richard W Stewart Solicitor : : - NJMBE iN J LCIu 1,, PENNSYLVANIA Gail A Nelson vs. Case Number Gregory A Nelson 2013-3626 SHERIFF'S RETURN OF SERVICE 07/24/2013 01:17 PM-Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2013 at 1317 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Novitas Solutions, 2020 Technology Parkway, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Karen Ryan, Executive Assistant 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 July 25, 2013 to Gregory A. Nelson, 1401 Walnut Street, Apt. 301, Philadelphia, PA 19102. NOTE: Novitas Solutions has moved from 1800 Center Street, Camp Hill, PA 17011 to the address where service was made at 2020 Technology Parkway, Mechanicsburg, PA 17050. There is no one associated with Novitas Solutions at 1800 Center Street that can accept service of civil papers. 02/26/2014 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: $99.12 SO ANSWERS, February 26, 2014 RONR ANDERSON, SHERIFF 424 9(1>© „04,t20?/92. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 3st i t/14 beg hy ESC P R O1 f H aO �i Jody S Smith Chief Deputy 20111 FEB 26 PM 2: r 6 Richard W Stewart �� Solicitor '1 UMBERLAND COUNT PENNSYLVANIA Gail A Nelson vs. Case Number Gregory A Nelson 2013-3626 SHERIFF'S RETURN OF SERVICE 07/03/2013 01:59 PM - Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 3, 2013 at 1359 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Highmark Inc., 1800 Center Street, Camp Hill, Cumberland County, Pennsylvania, 17011 by handing to Robin Walker, Executive Administrative Assistant, 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. 07/03/2013 01:59 PM - Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Highmark Medicare Services, Inc., but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Garnishment as "Not Served"at 1800 Center Street, East Pennsboro Township, Camp Hill, PA 17011. 07/03/2013 02:46 PM -Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on July 3, 2013 at 1440 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Gregory A. Nelson, in the hands, possession, or control of the within named garnishee, Highmark Medicare Services, Inc., NOW KNOWN AS Novitas Solutions, 2020 Technology Parkway, mechanicsburg, Cumberland County, Pennsylvania, 17055 by handing to Lisa Wolff, Legal Counsel, 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 July 8, 2013 to Gregory A. Nelson at 1401 Walnut Street,Apt. 301, Philadelphia,. PA 19102 (envelope provided by atty's office). 02/26/2014 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: $161.07 SO ANSWERS, W'4.11.2 February 26, 2014 RONR ANDERSON, SHERIFF 4,4 ,6fk 3a.-)/q/ N" -1418533_1 LANCE J. NELSON, ESQUIRE . ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY 1.0. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON Plaintiff VS. GREGORY A. NELSON Defendant and HIGHMARK MEDICARE SERVICES, INC. and HIGHMARK, INC. ATTORNEYS FOR PLAINTIFF -H r- -0 rs-0 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY; PENNA. : NO. 2013-03626 Garnishees PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against the Garnishee, Highmark, Inc., in the amount of $2,215.36 in the above-captioned matter "satisfied" upon payment of your costs only. Date: MacELREE HARVEY, LTD. By: (n cltd( Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff *so Po trmi elqipscoa 3cize.08 3 ''1418533 1 LANCE J. NELSON, ESQUIRE ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY I.D. NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street, P.O. Box 660 West Chester, PA 19381 -0660 (610) 436 -0100 GAIL A. NELSON Plaintiff vs. GREGORY A. NELSON Defendant and HIGHMARK MEDICARE SERVICES, INC. and HIGHMARK, INC. Garnishees ATTORNEYS FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. : NO. 2013 -03626 CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe to Satisfy Judgment Against Garnishee, Highmark, Inc. have been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Cecelia Rene Halligan First Class Mail March 2[1, 2014 120 Fifth Avenue, Ste. 2180 Pittsburgh, PA 15222 Sheryl R. Rentz, Esquire First Class Mail 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 Gregory A. Nelson First Class Mail 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 March 2%, 2014 March2l, 2014 MacELREE HARVEY, LTD. / By: 4."71/t Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff 04/03/20/4 THU 135O FAX 1219340_1 2011a1;01 2 Pi -I I: 45 LANCE J. NELSON, ESQUIRE - UMBERLCOUN„ATTORNEYS FOR PLAINTIFF ATTORNEY I.D. NO. 61059 CAQ LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 PENNSYLVAtil KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY 1.1), NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 GAIL A. NELSON IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff v. F. CIVIL ACTION - LAW GREGORY A. NELSON ; NO. 3L0,4 1401 Walnut Street, Apt9D4----1,005 Philadelphia, PA 19102 Defendant And HIGHMARK MEDICARE SERVICES,INC. 1600 Center Street Camp Hill, PA 17101 HIGHMARK, INC, 1800 Center Street Camp Hill, PA 17009-0426 Garnishees e-6,(Jakib etNAVQ1)-Cho PIOSOJUYZ-4 -17) INTERROGATORIES TO GARNISHEE TO: HIghmark, Inc. 1800 Center Street Camp Hill, PA 17089-0426 Q00 2/00 6 You are required to file answers to the following intenogatories within twenty (20) days after service upon you. Failure to do so may result In Judgment against you: 1. 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 the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? \ s 04/03/2014 THV 13:50 FAX 1219340_1 2. If the answer to Paragraph 1 is in the affirmative in any respect, please state: (a) How much you currently owe the defendant; $ 5, t --/D 1. ) Car' 1/1 ii\-6x/10/SEYilairs (b) How much you are liable to the defendant on any negotiable or other written instrument; rtk &H-ivou I. s 0 /021 z_i (÷15 LE I Ilte Pei--00bflik7c. Fli-e3 pi cLA tki 1t1-tv-r (s Vig---t_ib ge1li4--&20Er-6/-& TV -De-T-otibmjr• (c) How much the defendant claims that you owe the defendant or are liable to the defendant for? \ 3. At the time you were served or at any subsequent time was there in your possession, custody, or control or in the joint possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? 4. If the answer to Paragraph 3 is in the affirmative, please identify any and all such property and whether it was in your possession, custody, control, or in your joint possession, custody, or control? 04/03/2014 THV 13:50 FAX 1219340_1 11004/006 5. 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 defendant held or claimed any interest? 6. If the answer to Paragraph 5 is in the affirmative, please identify said property and state its monetary value? I j 7. At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the defendant had an Interest? SCE RESTseTD; 8. If the answer to Paragraph 7 is In the affirmative, please identify said property and state its monetary value. 9. 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 direction or consent and, if so, what was the consideration therefor and what was the property? 10. 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? J4/03/2014 TH0 13!50 FAX 12193401 11. If the answer to Paragraph 10 is in the affirmative, please state in detail the nature of said transaction. 12. At any time after you were served, did you hold legal title to property of the defendant, whether or not In fraud of creditors? I 13. if the answer to Paragraph 12 is in the affirmative, please identify in detail all such property. ®005/006 14. At any time after you were served, did you own or possess real property subject to a mortgage, judgment or other lien in which the defendant had an interest? 15. f the answer to Paragraph 14 is in the affirmative, please Identify all such properties in detail. 04/03/2014 THU 131 51 FAX 1219340_1 1Z006/006 16. Jr you are a bank or other financial Institution, at the time you were served or at any subsequent time did the defendant have funds on deposit In an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? if so, identify each account and state the reason for the exemption, the amount being withheld under each e emotion and the entity electronically depositing those funds on a recurring basis. 17. If you are a bank or other financial Institution, at the time you were served or at any subsequent time did the defendant have funds on deposit In an account In which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 § 6123? If so, Identify each account. MacELREE HARVEY, LTD. ey: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys for Plaintiff freig-z-/i4- 1-ham-Mi( 4i-1.6_,kcc)4_7() ---?/9-44-L66K_ 09, ,q6)v 1444929_1 LANCE J. NELSON, ESQUIRE ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 ATTORNEYS FOR PLAINTIFF GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff : NO. 2013-03626 vs. GREGORY A. NELSON 1401 Walnut Street Philadelphia, PA 19102 Defendant and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17101 Garnishees PRAECIPE FOR ENTRY OF JUDGMENT AGAINST GARNISHEE, HIGHMARK, INC. Pursuant to Pennsylvania Rules of Civil Procedure 3146(b) enter judgment in favor of plaintiff, Gail A. Nelson and against garnishee, Highmark, Inc. in the amount of $5,701.38 consistent with garnishee's Second Amended Answers to Interrogatories Nos. 1 and 2(a), a copy of which is attached hereto. MacELREE HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Attorneys for Plaintiff otmL %rG.saocl ok C 9��aa 12# issgq "011. s 04/W/2014 THU 13450 FAX 1219340_1 LANCE J. NELSON, ESQUIRE ATTORNEY 1.D NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO, 67267 KRISTIN A. MOLAVOQUE, ESQUIRE ATTORNEY 1,0, NO. 306844 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 ATTORNEYS FOR PLAINTIFF GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff v. : CIVIL ACTION - LAW GREGORY A. NELSON : NO, 1401 Walnut Street, Apt3.0-1-'1,005 Philadelphia, PA 19102 Defendant And HIGHMARK MEDICARE SERVICES,INC. 1800 Center Street • Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17089-0426 Garnishees PaAov.i)-c-h. --17) INTERROGATORIES TO GARNISHEE TO: HI hmark, Inc. 1800 Center Street Camp Hill, PA 17089-0426 ei) 0 2 / 0 0 6 You are required to file answers to the following inten-ogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you: 1. 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 the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? r 04/0.3/2014 aliv 13:5Q FAx 1219340_1 2, If the answer to Paragraph 1 is in the affirmative in any respect, please slate: (a) How much you currently owe the defendant; $5 1"10 • ) CL' IA e)- 11,11-10 5 (b) How much you are liable to the defendant on any negotiable or other written instrument; itt 1.416_fu s 1_1615 LE -RD pc -F- ftikir Ft Le --5 cLA ts ReityvOcieteL-& T9 A-) • (c) How much the defendant claims that you owe the defendant or are liable to the defendant for? 0003/006 3, At the time you were served or at any subsequent time was there in your possession, custody, or control or in the joint possession, custody, or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? 4. If the answer to Paragraph 3 is in the affirmative, please identify any and all such property and whether it was in your possession, custody, control, or In your joint possession, custody, or control? 04/0,/2014 THU 13:50 FAX 1219340_1 U004/006 5. 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 defendant held or claimed any interest? Iv 6. if the answer to Paragraph 5 is in the affirmative, please identify said property and state its monetary value? A-- 7, At the time you were served or at any subsequent time, did you hold as fiduciary any property in which the defendant had an interest? £e � X55 `C 8. If the answer to Paragraph 7 Is in the affirmative, please identify said property and state its monetary value. 9. 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 direction or consent and, if so, what was the consideration therefor and what was the property? 10. 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? 01/0/2010 THU 13:50 FAX 12193401 11. If the answer to Paragraph 10 is In the affirmative, please state in detail the nature of said transaction. 12. At any time after you were served, did you hold legal title to property of the defendant, whether or not in fraud of creditors? Nd 13. If the answer to Paragraph 12 is in the affirmative, please identify in detail all such property. ®005/006 14. At any time after you were served, did you own or possess real property subject to a mortgage, judgment or other lien in which the defendant had an interest? 15. f the answer to Paragraph 14 is in the affirmative, please identify all such properties in detail. 131/0?/2014 THU 131 51 FAX 1219340_1 0006/006 16. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit In an account in which funds are deposited electronically on a recurring basis and which are Identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each e emptlon and the entity electronically depositing those funds on a recurring basis. 17. If you are a bank or other financial Institution, at the time you were served or at any subsequent time did the defendant have funds on deposit In an account In which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa,C,S. § 8123? If so, Identify each account, MacELREE HARVEY, LTD. Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Kristin A. Molavoque, Esquire Attorneys fur Plaintiff C/6171e-ie /1779-7-77-/- 1-17 111-(4 k 1/q 64KL-- er-W L 1444929_1 LANCE J. NELSON, ESQUIRE ATTORNEY I.D. NO. 61059 LEO M. GIBBONS, ESQUIRE ATTORNEY I.D. NO. 67267 MacELREE HARVEY, LTD. 17 W. Miner Street P.O. Box 660 West Chester, PA 19381-0660 (610) 436-0100 ATTORNEYS FOR PLAINTIFF GAIL A. NELSON : IN THE COURT OF COMMON PLEAS 141 Pinkerton Road Coatesville, PA 19320 : CUMBERLAND COUNTY, PENNA. Plaintiff : NO. 2013-03626 vs. GREGORY A. NELSON 1401 Walnut Street Philadelphia, PA 19102 Defendant and HIGHMARK MEDICARE SERVICES, INC. 1800 Center Street Camp Hill, PA 17101 HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17101 Garnishees CERTIFICATE OF SERVICE This is to certify that in this case, complete copies of all papers contained in Praecipe for Entry of Judgment have been served upon the following persons, by the following means and on the date(s) stated: Name: Means of Service: Date of Service: Cecelia Rene Halligan Facsimile 412-544-7423 May 5 , 2014 120 Fifth Avenue, Ste. 2180 and First Class Mail Pittsburgh, PA 15222 Sheryl R. Rentz, Esquire 326 Lancaster Avenue, Ste. 100 Ardmore, PA 19003 First Class Mail May , 2014 1444929_1 Gregory A. Nelson 1401 Walnut Street, Apt. 301 Philadelphia, PA 19102 First Class Mail May , 2014 MacELREE HARVEY, LTD. By: Lance J. Nelson, Esquire Leo M. Gibbons, Esquire Attorneys for Plaintiff