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HomeMy WebLinkAbout01-5056SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 191 DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 COURT OF COMMON PLEAS CUMBERLAND PRAECIPE TO ENTER J-u-D~MENT TO THE PROTHONOTARY: Kindly enter judgment on behalf plaintiff, Little Data Center, Inc. and against defendant, Dr. John Paul Rebels, in the sum of $17,796.93. Attached hereto is a certified copy of a judgment entered in the Court of Common Pleas of Philadelphia County. I hereby certify that the above judgment is still due and owing. SANDLER & MARCHESINI, P.C. BY:/~~ /~AUL N. SANDLER, ESQUIRE Attorney for Plaintiff F: \WPFILES \ R\ ROSEN \DATACTR\ REHE IS \ Cumbe r land. Judgment. wpd SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 19125 DR. JOFIN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 COURT OF COMMON PLEAS Cumberland County CERTIFICATIO~ OF ADDRESEEE TO THE PROTHONOTARY: I hereby certify that the above stated address of plaintiff and defendant are true and correct. SANDLER & MARCHESINI, P.C. .UL N. S~ER, ESQUIRE Attorney for Plaintiff F: \ WPFIL~S \R \ROS EN\DATACTR\ REH~ IS \CERTIF2. wpd OFFICE Dr. Richard Reheis Lansdowne Tower Apartments Building A 770 Providence Road °Aldan, PA 19018 OF THE PROTHONOTARY COURT OF COUUON PLEAS :~4, CITY ii,ALI. · PHIf,~O~.,"HIA. PA. 19107 -LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 19125 DR. JOHN P~L REHEIS LANSDOWNE TOWER APARTMENTS BUILDING A - 770 PROVIDENCE ROAD Aldan, PA 19018 COURT OF COMUON PLEAS (Ph~ade!phia County) February Te~, 19 .... 99 No. 3552 NOTICE Pursuant to Rule 236 of ~e Supreme Court of Pennsylvania, you are hereby aotified J'ud~ent has ~en entered agm~sl yo~ in the a~ve groceedin[ as indicated below. IOHN }. PETTiT, ~X3ud~ent by Def~t [] Uoney Iudgment IF ATTORNEY at this telephone f-~ Iudgment in Replevin [] ~udgment for Possession [] ~udgment on Award of Arbi~afion ~ Jud~ent on VelVet ~ Jud~ent on Cou~ F~gs YOU HAVE ANY QUESTIONS CONCERNANG THIS NOTICE, PLEASE CALL: Paul N. Sandler, 568-9300 SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. 2315 East York Street Philadelphia, PA 191 DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 COURT OF COMMON PLEAs PHILADELPHIA COUNTy FEBRUARy TERM, NO. 35~ 1999 PP, AECIPE TO ENTER JUDGMENT AND ASSESS DAMAGES TO THE PROTHONOTARy: Kindly enter judgment on behalf plaintiff, Little Data Center, Inc. and against defendant, Dr. John Paul Rebels, for failure of defendant to answer plaintiff.s complaint within twenty (20) days. Kindly assess damages in the amount of $17,796.93. I certify that a Notice of Intent to Take Default Judgment was sent to the defendant on April 12, 1999, a true and correct copy Of said Notice is attached hereto and referred to as Exhibit "A". I further certify the above address is true and correct. SANDLER & MARC~{ESINi, P.C. Attorney for Plaintiff · SANDLER & MARCHESIN±, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTER, INC. : COURT OF COMMON PLEAS : PHILADELPHIA COUNTY VS. : FEBRUARY TERM, 1999 DR. JOHN PAUL REHEIS : NO. 3552 AFFIDAVIT OF NON MILITARY SERVICE Paul N. Sandler, Esquire, being duly sworn according to law, deposes and says that he represents the Plaintiff in the above matter; that he is authorized to make this Affidavit on behalf of the Plaintiff; and the above-named Defendant is over 18 years of age; the address of the Defendant is Lansdowne Tower Apartments, Building A, 770 Providence Road, Aldan, PA 19018; that the occupation of the Defendant is unknown; and that the Defendant is not in the Military Service of the United States nor any State or Territory thereof or its allies as defined in the Soldiers and Sailors Civil Relief Action of 1940 and the amendments thereto. SWORN TO AND SUBSCRIBED . 19 /. I, P.C. BY: ~ _9~U~ N. SANDLER, ESQUIRE Attorney for Plaintiff -2- SANDLER & MARCHESINI, P.C. BY: PAUL N. SANDLER, ESQUIRE Attorney I.D. #15711 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 (215) 568-9300 LITTLE DATA CENTsR, INC. 2315 East York Street Philadelphia, PA 19125 V'o DR. JOHN PAUL REHEIS Lansdowne Tower Apartments Building A 770 Providence Road Aldan, PA 19018 DATE OF NOTICE: April 12, 1999 TO: DR. JOHN PAUL REHEIS COURT OF COMMON PLEAS PHILADELPHIA COUNTy FEBRUARy TEP~M, 1999 NO. 355~ You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer ~. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: P~ILADELP~iA BAR ASSOCIATION LAWYER REFERENCE AND INFORMATION SERVICE One Reading Center Philadelphia, PA 19107 Telephone= (215) 238-1701 -~& MARCHESINI, P.C. B ~ P~UL N. SANDLER, ESQUIRE Attorney for Plaintiff REPORT : ZDRDOCT USER ID: COS First Judicial District CIVIL DOCKET REPORT CASE ID 990203552 PAGE 1 RUN DATE 08/17/01 RUN TIME 01:35 PM CASE NUMBER CASE CAPTION 990203552 LITTLE DATA CENTER INC VS REHEIS FILING DATE COURT LOCATION JURY 24-FEB-1999 AR AC N CASE TYPE: CONTRACTS OTHER STATUS: JUDGMENT BY DEFAULT/FINAL DISP Seq # Assoc Expn Date Type ID 1 APLF A15711 2 1 PLF @3928171 DFT @3928178 DGR @4075568 Party Name / Address & Phone NO. SANDLER, PAUL N 1429 WALNUT ST 16TH FLOOR PHILADELPHIA PA 19102 (000)568-9300 LITTLE DATA CENTER INC 2315 E YORK ST PHILADELPHIA PA 19125 REHEIS DR, JOHN PAUL LANSDOWNE TOWER APTS BLDG A 770 PROVIDENCE RD PRIMOS PA 19018 MADISON BANK 1767 SENTRY PARKWAY WEST BLUE BELL PA 19422 Filing Date / Time 24-FEB-99 16:15:00 24-FEB-99 16:15:00 24-FEB-99 16:15:00 Docket Entry COMMENCEMENT OF CIVIL ACTION SHERIFF'S SURCHARGE 1 DEFT COMPLAINT FILED NOTICE GIVEN SANDLER, PAUL N SANDLER, PAUL N 24-FEB-99 16:16:50 SANDLER, PAUL N COMPLAINT WITH NOTICE TO DEFEND WITHIN TWENTY (20) DAYS AFTER SERVICE IN ACCORDANCE WITH RULE 1018.1 FILED.ASSESSMENT OF DAMAGES NOT REQUIRED. ACTIVE CASE 25-FEB-99 10:28:29 ARBITRATION HEARING SCHEDULED REPORT : ZDRDOCT USER ID: COS First Judicial District CIVIL DOCKET REPORT CASE ID 990203552 PAGE 2 RUN DATE 08/17/01 RUN TIME 01:35 PM Filing Date / Time 08-MJ~R-99 16:20:00 17-MAY-99 12:19:00 24-FEB-00 13:47:00 29-MAR-00 11:54:00 24-APR-00 12:22:00 18-AUG-00 10:58:53 06-OCT-00 11:13:56 20-NOV-00 08:58:25 08-DEC-00 09:47:57 08-DEC-00 10:48:03 Docket Entry SHERIFF'S SERVICE SHERIFF'S SERVICE OF COMPLAINT ON DR. ON 3-8-99. JOHN PAUL REHEIS JUDGMENT BY DEFAULT/FINAL DISP 17,796.93 PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT FILED. JUDGMENT FOR PLAINTIFF(S) AGAINST DEFENDANT(S) FOR FAILURE TO FILE ANSWER WITHIN REQUIRED TIME. PRO-PROTHONOTARY NOTICE UNDER RULE 236. NOTICE UNDER 237.5. AFFIDAVIT OF NON-MILITARY SERVICE FILED DAMAGES ASSESSED $ 17,796.93 PRAECIPE TO ISSUE WRIT FILED SANDLER, PP, AECIPE FOR WRIT OF ATTACHMENT AGAINST MADISON BANK FILED. WRIT OF EXECUTION IN ATTACHMENT AND SUMMONS ISSUED UPON GARNISHEE. PAUL N ANSWERS-INTEROGS IN ATTACHMENT MADISON BANK, GARNISHEE ANSWERS TO INTERROGATORIES FILED. JUDGMENT ENTERED BY ADMISSION 721.77 SANDLER, PAUL N PP, AECIPE FOR ENTRY OF JUDGMENT FILED. JUDGMENT IN FAVOR OF PLAINTIFF AND AGAINST GARNISHEE MADISON BANK IN THE SUM OF $721.77 .. ADMITTED DUE IN ANSWER TO INTERROGATORIES FILED. NOTICE UNDER RULE 236. ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT THE PLAINTIFF'S MOTION TO COMPEL DISCOVERY IS GRANTED. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY, J 8-18-00 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT PLAINTIFFS MOTION TO COMPEL A DEPOSITION IS GRANTED. DEFENDANT PAY 300.00 FOR FILING. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY J. 10 06 00 ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT PLAINITFFS MOTION FOR CONTEMPT RULE RETURNABLE 12 08 00 IN COURTROOM 285. SEE ORDER FOR ADDITIONAL DETAILS. MCINERNEY J. 11 17 00 PARTIAL SATISFACTION FILED ORDER TO SATISFY THE JUDGMENT FILED AGAINST GARNISHEE MADISON BANK ORDER ENTERED/236 NOTICE GIVEN ORDERED THAT DEFENDANT, DR. JOHN PAUL REHEIS, IS HELD IN CONTEMPT OF COURT. THE DEFENDANT, DR. JOHN PAUL REHEIS, SHALL PAY THE PLAINTIFF'S COUNSEL THE SUM OF REPORT : ZDRDOCT USER ID: COS First Judicial District CIVIL DOCKET REPORT CASE ID 990203552 PAGE 3 RUN DATE 08/17/01 RUN TIME 01:35 PM Filing Date / Time Docket Entry $500.00 IN COUNSEL FEES FOR PREPARATION AND FILING OF THIS MOTION AND APPEARANCE IN COURT. SEE ORDER FOR ADDITIONAL DETAILS. WOLF, J 12/8/00 * * * End of Docket * * * Judgment certified in the amount of $17,796.93 CERTII:I]:DFRO~ITH[:IqI:CO.DON -AUG ! 8 2001 JOSEPH U. EVERS IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: LITTLE DATA CENTERS, INC. 2315 E. york Street ~hiladelphia, PA 19125 VS. · DR. JOHN PAUL REHEIS Lansdowne Tower Apts., Bldg. A ~70 Providence Road Aldan, PA 19018 & HtGtg~d~[, INC., GARNISHEE 1800 Center St, Camp Hill, PA 17089 TO THE PROTHONOTARY OF THE SAID COURT: ( ) Confessed Judgment (XX) Other File No. (~)1- ,~'~)C~::~ Amount Due $17,796.93 Interest $2,580.55 Atty's Comm Costs The undersigned hereby ce~e"~-that the betow does not arise out of a retail installment sale, contract, or account based on a confession of'j~lgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. IssUe writ of execution in the above matter to the Sheriff of for debt, interest and costs, upon the following described property of the defendant(s) County, PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) Any and all monies due and payable to Dr. John Paul Reheis including but not limited to all monies due or payable from Blue Cross, Blue Shield, Medicare and/or Medicard. (It is believed Dr. Reheis' and all other property of the defendant(s) in the possession, custody or control of the said garnish, ee(s),Pr.°~v.~e~ [~ (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the Date defendant(s) described in the attached exhibit. 0(~j- I~ ~.-00~. Signature: Print Name: Address: Attorney for: Telephone: Supreme Court ID No.: 1429 W~lm~f ~r~. 16th Pl nnr Philadelphia, PA 19102 Plaintiff (215) 568-9300 15711 (over) Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PAR..C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. SHERIFF'S RETURN - GARNISHEE CASE NO: 2001-05056 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND LITTLE DATA CENTER INC VS REHEIS JOHN PAUL DR And now SHANNON SUNDAY Cumberland County, Pennsylvania, to law, at 0014:10 Hours, on the 1st day of November , as herein commanded all goods, chattels, rights, debts, moneys of the within named DEFENDANT , REHEIS JOHN PAUL DR hands, possession, or control of the within named Garnishee HIGHMARK, INC 1800 CENTER ST , Sheriff or Deputy Sheriff of who being duly sworn according 2001, attached credits, and , in the CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to SALLY MCCOY (PARALEGAL) personally 3 true and attested copies of the within EXEMPLIFIED RECORD and made the contents thereof known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .O0 oo/oo/oooo~'~z? ,_ C' ' - Deputy Sheriff this [~-~ day of ~ j~o~ A.D. Proth~rfotary t · So answers: R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is retumed ABANDONED, no action taken in six months. SheriWs Costs: Docketing ! 8.00 Poundage 1.57 Advertising Law Library .50 Prothonotary 1. §0 Mileage 9.75 Misc. Surcharge 20. O0 Levy 20.00 Post Pone Sale Garnishee 9.00 80.32 Advance Costs: 150.00 Sheriffs Costs: 80.32 69.68 Refunded to Atty on 7 / 15/02 Sworn and Subscribed to before me this /6 ~day of ~x,~ So Answers; R. Thomas Kline, Sheriff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Ct~berland To satisfy the debt. interest and costs due COUNTY: Little Data Centers, NO. 01-5056 . CIVIL 1~X TEi:~v~ CIVIL ACTION - LAW PLAINTIFF(S) from Dr. John Paul Reheis, Lansdowne Tower Apts., Bldg. A, 770 Providence Road, Aldan, PA 19018 DEFENDANT(S) (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 __ Any and all monies due and payable to Dr. John Paul Reheis including but not limited t~ ~11 m,-,n~,=~ ~,p ~r ~y~b]~ frcrn Bl%]e Cross. Blue Shield. Medicare and/or Medicard. (It is believed Dr. Reheis' provider ngrnber is 199935) Hiqh~ark, Inc., Garnishee, 1800 Center St., Can~3 Hill, PA 17089 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are 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 Iound in lhe possession of anyone other than a named garnishee, you are directed to notify him/he r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $17,796.93 L.L. $.50 Interest $2,580.55 Due Prothy S1.00 Atty's Comm % Other Costs $. 50 Due Garnishee Arty Paid $32.50 Plaintiff Paid Date: October 23, 2001 Curtis R. Long REQUESTING PARTY: Name Paul N. Sandler, Esq. Address: 1429 Walnut Street, 16th Floor Philadelphia, PA 19102 Atlorney for: Plaintiff Telephone: 215-568-9300 Prothonotary, Civil Division (__ Deputy Supreme Court ID No. 15711