Loading...
HomeMy WebLinkAbout02-2764STEVENS & LEE By: Kenneth D. Kleinman I.D. No.: 31770 One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 Telephone: (610) 293-4968 Affiliated Community Medical Centers, P.A. Plaintiff V. John T. Irwin Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Pursuant to 42 Pa.C.S.A. §4305 and Pennsylvania Rule of Civil Procedure 3002, kindly enter judgment in favor of the plaintiff, Affiliated Community Medical Centers, P.A., and against the defendant, John T. Irwin, in the amount of $84,131.16 in accordance with the attached certified copy of all docket entries and the certification of the amount of the judgment of docket number 01-5617 of the United States District Court for the Eastern District of Pennsylvania, and index said judgment against the defendant. Dated: ~/~ 2002 STEVENS & LEE By: Kenneth D. Kleinman Attorneys For Plaintiff' Affiliated Community Medical Centers, P.A. SL1 267205vl/32559.001 IN THE UNITED STATES DISTRICT COURT FORI~E~ EASTERN DISTRICT OF rSYLVANiA Affiliated Commu~ity : CIV~ ACTION Medical Centers, P.A. ?iLED : John T. Irwin ~ : No. 01-5617 [,~~KUNZ, Clerk Bl'~clerk AND NOW, th~ llth ~ay of February, ~D02, upon entry of default (#8),JU~4ENT. IS ENTERED for pl~htiff Affiliated Community Medical ~enters, P.A., and against defendant John T. Irwin, M.D., in the amount of $84,131w16. Norma L. Shapiro S.J. TRUE COPY C~11FI£D' FROM THE.RECORD DATED: .. ATTEST: ~TF..RN [ STRICT OF P£NNSYLVANI~ f-STND CLOSED U.S. District Court U.S. District Court of Eastern Pennsylvania (Philadelphia) CIVIL DOCKET FOR CASE #: 01-CV-5617 AFFILIATED COMMUNITY v. IRWIN Assigned to: JUDGE NORMAL. SHAPIRO Demand: $0,000 Lead Docket: None Dkt# in other court: None Filed: 11/07/01 Nature of Suit: 190 Jurisdiction: Diversity Cause: 28:1332 Diversity-Breach of Contract AFFILIATED COMMUNITY MEDICAL CENTERS, P.A. PLAINTIFF BRIAN P. CROWNER [COR LD NTC] STEVENS & LEE ONE GLENHARDIE CORPORATE CENTER, SUITE 202 1275 DRUMMERS LANE, P.O. BOX 236 WAYNE, PA 19087-0236 USA TEL 610-964-1480 JOHN T. IRWIN, M.D. DEFENDANT Docket as of April 25, 2002 4:04 pm Page 1 P~oceedings include all events. 2:01cv5617 AFFILIATED COMMUNITY v. IRWIN ii/7/Oi ii/7/Oi -- ii/7/Oi -- ll/7/Oi -- ii/9/Oi 2 ii/20/O1 3 ii/26/0i 4 12/3/01 5 12/26/01 6 1/3/02 7 1/3/02 1/3/02 -- 1/9/02 8 2/4/o2 9 2/14/02 10 f-STND CLOSED Complaint. filing fee $ 150 receipt # 775496 (ss) [Entry date 11/07/01] Summons(es) issued, One original Forwarded to: counsel 11/7/01 (ss) [Entry date 11/07/01] Standard Case Management Track. (ss) [Entry date 11/07/01]i Case is eligible for arbitration. (ss) [Entry date 11/07/~1] ORDER THAT A HEARING ON A RULE TO SHOW CAUSE WHY THIS CAS~ SHOULD NOT BE DISMISSED FOR LACK OF JURISDICTION WILL BE HELD ON 11/16/01 AT 10:00 ( SIGNED BY JUDGE NORMAL. SHAPIRO ) 11/9/01 ENTERED AND COPIES MAILED. (jl) [Entry date 11/09/01] ORDER THAT THE RULE TO SHOW CAUSE IS VACATED, PLAINTIFF SHALL FILE AN AMENDED COMPLAINT ON OR BEFORE 11/30/01, ETC. ( SIGNED BY JUDGE NORMAL. SHAPIRO ) 11/21/01 ENTERE£ AND COPIES MAILED (il) [Entry date 11/21/01] Amended complaint by PLAINTIFF AFFILIATED COMMUNITY , amending [1-1] complaint , Certificate of Service. (jl) [Entry date 11/26/01] Affidavit of: TOM FREDERICKS re: served summons and complaint upon DEFENDANT JOHN T. IRWIN . Served by: personal service on 11/16/01 (ke) [Entry date 12/03/01] Affidavit of Brian P. Crowner, Esquire, Certificate of Service. (jl) [Entry date 12/27/01] Request for an entry of judgment by default by PLAINTIFF AFFILIATED COMMUNITY as to DEFENDANT JOHN T. IRWIN, certificate of service. (jl) [Entry date 01/03/02] Default by DEFENDANT JOHN T IRWIN for failure to appear, plead or otherwise defend, ijl) [Entry date 01/04/02] DEFAULT ENTERED. (jl) [Entry date 01/04/02] ORDER THAT PLAINTIFF'S MOTION FOR AN ENTRY OF JUDGMENT BY DEFAULT IS GRANTED IN PART. DEFAULT IS ENTERED AGAINST JO~ T. IRWIN, TO ENABLE THE COURT TO ENTER JUDGMENT, A HEARIN~ TO ASSESS DAMAGES UNDER F.R.C.P. 55 (b) (2) WILL BE HELD 2/7/02 AT 9:30 IN COURTROOM 10-A ( SIGNED BY JUDGE NORMA L. SHAPIRO ) 1/10/02 ENTERED AND COPIES MAILED . (jl) [Entry date 01/10/02] Affidavit of TERRY R. TONE (jl) [Entry date 02/05/02] ORDER THAT JUDGMENT IS ENTERED for AFFILIATED COMMUNITY against JOHN T. IRWIN for $84,131.16. 2/15/02 ENTERED AND COPIES MAILED ( SIGNED BY JUDGE L. SHAPIRO ) (jl) Docket as of April 25, 2002 4:04 pm Page 2 Proceedings include all events. 2:01cv5617 AFFILIATED COMMUNITY v. IRWIN [Entry date 02/15/02] 2/14/02 -- Case closed (ky) [Entry date 02/15/02] CLOSED f-STND Docket as of April 25, 2002 4:04 pm Page 3 STEVENS & LEE By: Kenneth D. Kleinman I.D. No.: 31770 One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 Telephone: (610) 293-4968 Affiliated Community Medical Centers, P.A. · John T. Irwin Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CERTIFICATION OF ADDRESSES The undersigned hereby certifies that he is counsel for the plaintiff in the above captioned matter and that he is authorized to make this certification on plaintiffs behalf and that the last known address of the defendant is 1619 Makefield Road, Yardley, Pennsylvania 19067 and that the last known address of the plaintiff is 101 Willmar Avenue SW, Willmar, Minnesota 56201. Dated: ~/3 , 2002 STEVENS & LEE By: Kenneth D. Kleinman Attorneys For Plaintiff Affiliated Community Medical Centers, P.A. SLI 267205vi/32559.001 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CHESTER SS. Kenneth D. Kleinman, being duly sworn according to law, deposes and says that he is counsel for plaintiff, Affiliated Community Medical Centers, P.A. ("Plaintiff"). Deponent further avers that the last known address of the defendant, John T. Irwin ("Defendant") is 1619 Makefield Road, Yardley, Pennsylvania 19067, and that the Defendant is over 21 years of age. Deponent further avers that the present occupation of the Defendant is a medical doctor, and that Defendant is not believed to be a member of the armed forces of the United States, and is not in any manner under the jurisdiction of the Soldiers' and Sailors' Civil Relief Act of 1940 and/or its amendments./_,~ a>~ ~~~/(/~'79~;f~~_ : Kenneth D. Kleinman Swor~ ~2 and subscribed before me this ~/¢~' day of ?~--, Notary Public /d/ NOTARIAL SEAL j VAt. ERIE J. ECKERT, Notary Public Wayne, Chester Counly I My Commission Expire~ March 5, 2005 2002. SL1 267215vl/32559.001 -<2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW (Rule of Civil Procedure No. 236) - Rcviscc[ To: John T. Irw/n 1619 Makefield Road Yardley, PA 19067 Affiliated Community Medical Centers, P.A. · Plaintiff · John T. Irwin Defendant COURT OF COMMON PLEAS (Cumberland County) NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. CURT LONG Prothonotary {2 Judgment by Default [] Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration Judgment on Verdict Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Kenneth D. Kleinman, Esquire [/nsert Attorney's Name) at this telephone number: (610) 293-4968 10-232 [Editor's note: This form reproduced for information only. Counsel must use original form from the prothonotary.] SL1 267205vl/32559.001 Commonwealth of Pennsylvani COUNTY OF CUMBERLAND AFFILIATED COMMUNITY MEDICAL CEN IERS, P.A. 101 Willmar Avenue SW Willmar, MN 56201, JOHN T. IRWIN 1619 Makefield Road Yardley, PA 19067, and PENNSYLVANIA BLUE SHIELD 1800 Center Street Camp Hill, PA 17089 Plaintiff Defendant HIGHMARK, INC. 1800 Center Street Camp Hill, PA 17089 SL1 270877vl/32559.001 COURT OF COMMON NO. 02-2764 Garnishees (applicable to real estate and personal propert~ PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against John T. Irwin 1619 Makefield Road Yardley, PA 19067 ?LEAS (2) against PeImsylvania Blue Shield 1800 Center Street Camp Hill, PA 17089 (3) Highmark, It 1800 Center ]treet Camp Hill, A 17089 $ $180.00 AMOUNT DUE INTEREST from 6/7/02 at 6% per annum ($7.20 per diem) until the amount due is paid in full co tstobead e , & zcc Attorney(s) for Plaintiff(s) Kenneth D. Kleinman defendant(s) and garnishee(s) $43,189.36 (applicable to real estate only) Rule 3104(a) TO THE PROTHONOTARY: (4) Issue this writ against Attorney(s) fo (applicable to real estate only) Rule 3104(a) TO THE PROTHONOTARY: (5) Issue this writ against as a lis pendens against real property of the defendant(s) in name of gar (Specifically describe property.) ~t~57~¢ Attorney(s) SL1 270877vl/32559.001 defendant(s) and Plaintiff(s) as garnishee(s) ishee(s) as follows. · Plaintiff(s) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-T COUNTY OF CUMBERLAND) C] TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AFFILIATED COMMUNITY P.A., Plaintiff (s) From JOHN T. IRWIN, 1619 MAKEFIELD ROAD, YARDLEY, PA 1906 (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 up of PENNSYLVANIA BLUE SHIELD, 1800 CENTER STREET, CAMP HIL HIGHMARK, INC., 1800 CENTER STREET, CAMP HILL, PA 17089 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gain paying any debt to or for the account of the defendant (s) and from delivering any (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is fm of anyone other than a named garnishee, you are directed to notify him/her that h~ garnishee and is enjoined as above stated. Amount Due $43,189.36 L.L. $.50 Interest FROM 6/7/02 AT 6% PER ANNUM ($7.20 PER DIEM) UNTIL TH PAID IN FULL Atty's Comm % Due Prothy $1.00 Atty Paid $32.50 Other Costs Plaintiff Paid Date: JUNE 21, 2002 (Seal) CURTIS R. LONG ~ ~ ~Pr°th°n°5'rY? Deput) REQUESTING PARTY: Name KENNETH D. KLEINMAN, ESQUIRE Address: STEVENS & LEE ONE GLENI-IARDIE CORPORATE CENTER 1275 DRUMMERS LANE P.O.BOX 236 WAYNE, PA 19087-02346 Attorney for: PLAINTIFF Telephone: 610-293-4968 Supreme Court ID No. 31770 ~64 Civil VIL ACTION - LAW VIEDICAL CENTERS, ~ in the possession L, PA 17089 AND shee(s) is enjoined from property of the defendant ad in the possession tshe has been added as a AMOUNT DUE IS SHERIFF'S RETURN - CASE NO: 2002-02764 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GARNISHEE AFFILATED COMMUNITY MEDICAL VS IRWIN JOHN T And now GERALD WORTHINGTON ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:00 Hours, on the 26th day of June , 2002, attached as herein commanded all goods, chattels, rights, moneys of the within named DEFENDANT , IRWIN JOHN T debts, credits, and , in the hands, possession, or control of the within named Garnishee PENNSYLVANIA BLUE SHIELD 1800 CENTER STREET CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to SALLY MCCOY (PARALEGAL) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So an s~ r~. ~-~ R. Thomas Kline Sheriff of Cumberland County oo/oo/oooo Sworn and subscribed to before me this ~ day of~ ~/~.z- A.D. P~othonot ary DepUty 'S~rif f SHERIFF'S RETURN CASE NO: 2002-02764 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND - GARNISHEE AFFILATED COMMUNITY MEDICAL VS IRWIN JOHN T And now GERALD WORTHINGTON ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:00 Hours, on the 26th day of June , 2002, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , IRWIN JOHN T , in the hands, possession, or control of the within named Garnishee HIGHMARK INC 1800 CENTER STREET CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to SALLY MCCOY (PARALEGAL) ' personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 R. Thomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this ~- day o~ ~omD_ A.D. ps'or;honor ary Deputy St~r i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFILIATED COMMUNITY MEDICAL CENTERS, P.A., Plaintiff No: 02-2764 Ye JOHN T. IRWIN, Defendants ANSWERS TO INTERROGATORIES IN AID OF ATTACHMENT PENNSYLVANIA BLUE SHIELD, and HIGHMARK INC., Garnishees Answers to Interrogatories Directed to Garnishee Filed on behalf off HIGHMARK INC., Garnishee Counsel of Record for this party: Edward Papst, Esquire Pa. I.D. 62967 Fifth Avenue Place, Suite 2180 120 Fifth Avenue Pittsburgh, PA 15222-3099 (412) 544-7213 STEVENS & LEE BY: Kenneth D. Kleinman, Esquire IDENTIFICATION NO.: 31770 One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 (610) 293-4968 AFFiLIATED COMMUNITY MEDICAL CENTERS, P.A., Plaintiff Attorney for Plaintiff, Affiliated Community Medical Centers, P.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY JOHN T. IRWIN, NO. 02-2764 Defendant and PENNSYLVANIA BLUE SHIELD, and HIGHMARK, INC. Garnishees INTERROGATORIES IN AID OF ATTACHMENT TO: Highmark, Inc. 1800 Center Street Camp Hill, PA 17089 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(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason and, if so, state how much money you owe the defendant(s) and the basis of such liability? No. Defendant's coverage with Highmark Inc. d/b/a Pennsylvania Blue Shield canceled January 15, 2000. SL1 270877vl/32559.001 2. 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 persons any property of any nature owned solely or in part by the defendant(s) and, if so, identify such property and state its value and location? 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest and, if so, identify such property and your legal title to or interest in it and state such properties value and location? No. 4. At the time you were served or at any subsequent time did you hold as a fiduciary any property in which the defendant(s) had any interest and, if so, identify such property, state its value and location, and state the nature of your fiduciary interest in it? NO. 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, identify such property, state the date it was delivered to you, state what, if any, consideration was paid in exchange for the transfer of such property and state the location of such property? No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to defendant(s) direction or otherwise discharge any claim of the defendant(s) against you and, if so, identify what money or property was paid, transferred or delivered to the defendant(s), state when such payment, transfer or delivery occurred and state the amount of money or value of the property that was transferred or delivered to the defendant(s)? No. SL1 270877vl/32559.001 7. At any time before or after you were served did the defendant(s) have any savings accounts, checking accounts, certificates of deposit or safety deposit boxes which you were holding? If so, please identify the title and number of the account and the amount of any balance? NO. Dated: Stevens & Lee Kenneth D. Kleinman Attorney for Plaintiff One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 (610) 293-4968 H IG~4ARK INC. Edward Papst Attorney for Garnishee Fifth Avenue Place, Suite 2180 120 Fifth Avenue Pittsburgh, PA 15222 (412) 544-7213 PA ID~ 62967 SL1 270877vl/32559.001 VERIFICATION I, Edward Papst, Assistant Counsel of Highrnark Inc. d/b/a Pennsylvania Blue Shield, verify that the statements made herein are true and correct to the best of my knowledge, infom~ation and belief and are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unswom falsification to authorities. Date: July 5, 2002 Edward Papst, Esquire Assistant Counsel CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Answers to Interrogatories in Aid of Attachment were mailed by US Mail 1 st class, post~ge prepaid this 5th day of July, 2002 to the following: Kenneth D. Kleinman, Esquire One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 Edward Papst, Esquire Pa. I.D. 62967 Highmark Inc. d/b/a Pennsylvania Blue Shield 120 Fifth Avenue Place, Suite 2180 Pittsburgh, PA 15222-3099 (412) 544-7213 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA AFFILIATED COMMUNITY MEDICAL CENTERS, P.A., Plaintiff No: 02-2764 JOHN T. IRWIN, Defendants ANSWERS TO INTERROGATORIES IN AID OF ATTACHMENT Ye PENNSYLVANIA BLUE SHIELD, and mGHMARK INC., Garnishees Answers to Interrogatories Directed to Garnishee Filed on behalf oE PENNSYLVANIA BLUE SHIELD, Garnishee Counsel of Record for this party: Edward Papst, Esquire Pa. I.D. 62967 Fifth Avenue Place, Suite 2180 120 Fifth Avenue Pittsburgh, PA 15222-3099 (412) 544-7213 STEVENS & LEE BY: Kenneth D. Kleinman, Esquire IDENTIFICATION NO.: 31770 One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 (610) 293-4968 AP'FILIATED COMMUNITY MEDICAL CENTERS, P.A., Plaintiff JOHN T. IRWIN, Defendant Attorney for Plaintiff, Affiliated Community Medical Centers, P.A. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 02-2764 and PENNSYLVANIA BLUE SHIELD, and HIGH/VIARK, INC. Garnishees ANSWB~S ~ INTERROGATORIES IN AID OF ATTACHMENT TO: Pennsylvania Blue Shield 1800 Center Street Camp Hill, PA 17089 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(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason and, if so, state how much money you owe the defendant(s) and the basis of such liability? No. Defendant's coverage with Highmark Inc. d/b/a Pennsylvania Blue Shield canceled January 15, 2000. SL1 270877vl/32559.001 2. 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 persons any property of any nature owned solely or in part by the defendant(s) and, if so, identify such property and state its value and location? Bio. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant(s) or in which defendant(s) held or claimed any interest and, if so, identify such property and your legal title to or interest in it and state such properties value and location? NO. 4. At the time you were served or at any subsequent time did you hold as a fiduciary any property in which the defendant(s) had any interest and, if so, identify such property, state its value and location, and state the nature of your fiduciary interest in it? BIO. 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and, if so, identify such property, state the date it was delivered to you, state what, if any, consideration was paid in exchange for the transfer of such property and state the location of such property? No. 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to defendant(s) direction or otherwise discharge any claim of the defendant(s) against you and, if so, identify what money or property was paid, transferred or delivered to the defendant(s), state when such payment, transfer or delivery occurred and state the amount of money or value of the property that was transferred or delivered to the defendant(s)? No. SL1 270877vl/32559.001 7. At any time before or after you were served did the defendant(s) have any savings accounts, checking accounts, certificates of deposit or safety deposit boxes which you were holding? If so, please identify the title and number of the account and the amount of any balance? BIO. Dated: Stevens & Le~g ~ Kenneth D. Kleinman Attorney for Plaintiff One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 (610) 293-4968 P~qNSYLVANIA BLUE SHIELD Edward Papst Attorney for Garnishee Fifth Avenue Place, Suite 2180 120 Fifth Avenue Pittsburgh, PA 15222 (412) 544-7213 PA ID~ 62967 SL1 270877vl/32559.001 VERIFICATION I, Edward Papst, Assistant Counsel of Highmark Inc. d/b/a Pennsylvania Blue Shield, verify that the statements made herein are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unswom falsification to authorities. Date: July 5, 2002 Edward Papst, Esquire Assistant Counsel CERTIFICATE OF SERVICF~ I hereby certify that a true and correct copy of the foregoing Answers to Interrogatories in Aid of Attachment were mailed by US Mail st this 5th day of Juiy, 2002 to the following: 1 class, postage prepaid Kenneth D. Kleinman, Esquire One Glenhardie Corporate Center 1275 Drummers Lane P.O. Box 236 Wayne, PA 19087-0236 Edward Papst, Esquire Pa. I.D. 62967 Highmark Inc. d/b/a Pennsylvania Blue Shield 120 Fifth Avenue Place, Suite 2180 Pittsburgh, PA 15222-3099 (412) 544-7213 STEVENS & LEE BY: KENNETH D. KLEINMAN IDENTIFICATION NO. 31770 ONE GLENHARDIE CORPORATE CENTER 1275 DRUMMERS LANE P.O. BOX 236 WAYNE, PA 19087-0236 (610) 293-4968 AFFILIATED COMMUNITY MEDICAL CENTERS, P.A. JOHN T. IRWIN, and Plaintiff, Defendant, PENNSYLVANIA BLUE SHIELD, and HIGHMARK, INC. Garnishees ATTORNEYS FOR PLAINTIFF, Affiliated Community Medical Centers, P.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO. 02-2764 PRAECIPE TO DISSOLVE ATTACHMENT AS TO GARNISHEES PENNSYLVANIA BLUE SHIEI,D, AND HIGHMARK~ INC. TO THE PROTHONOTARY: Please dissolve the attachment issued in the above-captioned matter as to garnishees Pennsylvania Blue Shield, and Highmark, Inc. Date: July q , 2002 STEVENS j~L ~EE .,~ Kenneth D. Kleinman, Esquire Attorneys for Affiliated Community Medical Centers, P.A. SL1 276292vl/32559.001 CERTIFICATE OF SERVICE I, Kyle D. Gibson, hereby certify that I am a paralegal with the law firm of Stevens & Lee, and that on the date set forth below I caused to be served a tree and correct copy of the foregoing Praecipe to Dissolve Attachment as to Garnishees Pennsylvania Blue Shield, and Highmark, Inc. upon the following by first-class U.S. mail, postage prepaid, addressed as follows: John T. Irwin 1619 Makefield Road Yardley, PA 19067 Edward Papst, Esquire Fifth Avenue Place, Suite 2180 120 Fifth Avenue Pittsburgh, PA 15222-3099 Dated: July lo ,2002 Kyle D./~iibson SL1 276292vl/32559.001 STEVENS & LEE BY: KENNETH D. KLEINMAN IDENTIFICATION NO. 31770 ONE GLENHARDIE CORPORATE CENTER 1275 DRUMMERS LANE P.O. BOX 236 WAYNE, PA 19087-0236 (610) 293-4968 ATTORNEYS FOR PLAINTIFF, Affiliated Community Medical Centers, P.A. AFFILIATED COMMUNITY MEDICAL CENTERS, P.A., JOHN T. IRWIN, Plaintiff, Defendant, and PENNSYLVANIA BLUE SHIELD and HIGHMARK, INC., Garnishees CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL ACTION NO. 02-2764 PRAECIPE FOR SATISFACTION OF JUDGMENT AS TO DEFENDANT JOHN T. IRWIN, AND TO MARK CASE SETTLED DISCONTINUED AND ENDED TO THEPROTHONOTARY: Please mark the judgment entered on or about June 6, 2002 in the amount of $84,131.16 satisfied of record as to defendant John T. Irwin, and mark the case settled discontinued and ended upon payment of your costs only. Date: August ~, 2002 STEVENS & LEE Kenneth D. Kleinman, Esquire Attorneys for Affiliated Community Medical Centers, P.A. SLI 283076vl/32559.001 CE.~RT/FICATE OF SERVICE I, Kyle D. Gibson, hereby certify that I am a paralegal with the law firm of Stevens & Lee, and that on the date set forth below I caused to be served a true and correct copy of the foregoing Praecipe for Satisfaction of Judgment as to Defendant John T. Irwin, and to Mark Case Settled, Discontinued and Ended upon the following by first-class U.S. mail, postage prepaid, addressed as follows: John T. Irwin 1619 Makefield Road Yardley, PA 19067 Gregory C. McCarthy, Esquire 99 E. Court Street Doylestown, PA 18901 Dated: August ~ ~3 , 2002 SLI283076vl/32559.001 :3' R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 2.35 Advertising Law Library .50 Prothonotary 1.00 Mileage 10.35 Misc. Surcharge 30.00 Levy 40.00 Post Pone Sale Garnishee 18.00 120.20 Advance Costs: Sheriff's Costs: Refunded to Atty on 150.00 120.20 29.80 3/25/03 Sworn and Subscribed to before me this j"& day of 2003 A.D.C'~L~z,,.~ P~'o(honotary So Answers; R. Thomas Kline, Sheriff By..'. fr~_i~J_,,,.., ·