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Home My WebLink About01-5612/cla/slc//Praecipe for Wr/t of SummonsSeptember 26, 2001 4:27 PM JANET L. PRAVE and NICK THOMAS PRAVE, 213 Grant Street Sykesville, PA PLAINTIFFS SAMBHU KUNDU, M.D. and GEORGE E. JEFFERIES, III, M.D., 890 Poplar Church Road Camp Hill, PA DEFENDANTS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - AT LAW JURY TRIAL DEMANDED PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY: Please issue Writs of Summons and deliver them to the Sheriff for service on the defendants at the above address. Respectfully submitted, Date: SMIGEL, ANDERSON & SACKS C. ESe/Anderson, Esquire I.D. #:' 21315 2917 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiffs Commonwealth of Pennsylvama County of Cumberland JABOT L. PRAVE AND NICK THCb~hS PRAVE 213 Grant Street Sykesville, PA SAMBHUKI3NDU, M.D. AND GEORGE E. JEFFERIES, ~II. M.D., 890 Poplar Church Roao Camp Hill, PA Court of Con~mon Plem No. 01-5612 Civil Term ...... 19 In civil Action Law To---S--Ali~---H~3---KLr2~--UL-M-'D-'-~-~z2QE~,-J3EFFERIES' III, M.D. You are hereby notified that ..... JASIET- k.-_PP, A-VE _AND--hlJ-CK-TI:KI"J/~S- _RRA.V~. ................................................. the Plaintiff ha commenced an action in --S---mI~----n-s------qi-Y-i-1--A--c-t-i-qn--r--L-a--w ..................... against you which you are required to defend or a default judgment may be entered against you. (SEAL) Date Sept__erfl_~r ~j 2QQ1 ...... 19 .... Prothonotary SHERIFF' S RETURN CASE NO: 2001-05612 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRAVE JANET L ET AL VS KUNDU SAMBHU MD ET AL - REGULAR DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within WRIT OF SUMMONS was served upon KUNDU SAMBHU MD the DEFENDANT , at 1400:00 HOURS, at 890 POPLAR CHURCH ROAD on the 1st day of October , 2001 CAMP HILL, PA 17011 CONNIE OSGOOD, OFFICE MANAGER by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing .Her attention to the contents thereof. Sheriff.s Costs: Docketing 18.00 Service 9.75 Affidavit .00 Surcharge 10.00 .00 37.75 Sworn and Subscribed to before me this ¥ ~ day of 0~ ~-~ A.D. t~rdthonotary So Answers: R. Thomas Kline 10/02/2001 s iGEL & sA0 Deputy Sheriff SHERIFF' S RETURN - REGULAR CASE NO: 2001-05612 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PRAVE JANET L ET AL VS KUNDu SAMBHU MD ET AL DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within WRIT OF SUMMONS was served upon JEFFERIES GEORGE E III MDthe law, DEFENDANT , at .1400:00 HOURS, on the at 890 POPLAR CHURCH ROAD 1st day of ~ctober , 2001 CD24P HILL, PA 17011 CONNIE OSGOOD, OFFICE MANAGER by handing to a true and attested copy of WRIT OF SUMMONS together with and at the same time directing ~er attention to the contents thereof. Sheriff,s Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of ~ ~ZOz~ / A.D. otary " So Answers: R. Thomas Kline 10/02/2001 SMIGEL ANDERSON & SACKS By: ~ ~__~ Dephty Sheriff FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 Fax: (717) 213-4202 JANET L. PRAVE AND NICK THOMAS PRAVE Plaintiffs SAMBHU KUNDU, M.D. AND GEORGE E. JEFFERIES, III, M.D. Defendants CUMBERLAND COUNTY, CIVIL ACTION LAW NO. 01-5612 Attorneys for Defendants: Sambhu Kundu, M.D. and GeorGe E. Jeffries, III, M.D., P.C. IN THE COURT OF CO~ON PLEAS PENNSYLVANIA J73RY TRIAL DEMANDED PP~AECIPE TO ENTER APPEARANCE TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Kindly enter our appearance as counsel on behalf of Defendants, Sambhu N. Kundu, M.D. and George E. Jefferies, M.D., in the above-captioned matter. III, By: Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPOP~ATION Attorney ~D. No. 53229 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing ENTRY OF APPEARANCE was served upon counsel of record this 16th day of October, 2001, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harrisburg, PA 17110 FOULKROD ELLIS PROFESSIONAL CORPORATION Klmb~rly J~h~e, Paralegal FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 Fax: (717) 213-4202 JANET L. PRAVE AND NICK THOMAS PRAVE Plaintiffs : SAMBHU KUNDU, M. D. AND : GEORGE E. JEFFERIES, III, M.D.: Defendants : Attorneys for Defendants: Sambhu Kundu, M.D. and George E. Jeffries. III. M.D.. P.C, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Please issue a Rule upon Plaintiffs to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros· FOULKROD ELLIS PROFESSION/~ CORPORATION Date: ~ 0-/~ ~1 By: f~.,/'~. ~ Leigh A.J. ~llls, ESQUIRE ' Attorney I.~. No. 53229 RULE TO THE PLAINTIFFS: You are hereby ordered and directed to file your Complaint against Defendants, Sambhu N. Kundu, M.D. and George E. Jefferies, III, M.D., in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non pros. ~~ar~y~, C-~d County CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE FOR RULE TO FILE COMPLAINT was served upon counsel of record this 16th day of October, 2001, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harrisburg, PA 17110 FOULKROD ELLIS PROFESSIONAL CORPOP~ATION Ki~b~ly J. o~u~, Paralegal FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 ~x: (717) 213-4202 JANET L. PP~AVE AND NICK THOMAS PP~AVE Plaintiffs SAMBHU KUNDU, M. D. AND GEORGE E. JEFFERIES, III, M.D. Defendants Attorneys for Defendants: Sambhu Kundu, M.D. and Georqe E. Jeffries. III. M.D., P.C. IN THE COURT OF CO~40N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 JURY TRIAL DEMANDED PRAECIPE TO FILE A CERTIFICATE OF SERVICE TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Kindly file of record the attached Certificate of Service of the RULE TO FILE A COMPLAINT, which was issued on October 17, 2001, and served on the date reflected in the attached Certificate of Service. Respectfully Submitted, FOULKROD ELLIS ~GoHrneA~ ~53E2S 2Q9uIR~~E- FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: {717) 213-%200 Fa.x: (717) 213-4202 JANET L. PPJ%VE AND NICK THOMAS PRAVE Plaintiffs SAMBHU KUNDU, M.D. AND GEORGE E. JEFFERIES, III, Defendants M.D. Attorneys for Defendants: Sambhu Kundu, M.D. and Geor=e E. Jeffries. III. M.D.. P.C. IN THE COURT OF COMMON PLEAS PENNSYLVANIA CUMBERLAND COUNTY, CIVIL ACTION LAW NO. 01-5612 JURY TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Please issue a Rule upon Plaintiffs to file a Complaint within twenty (20) days from service hereof or suffer judgment non pros. Date: FOULKROD ELLIS PROFESSION~L CORPORATION By: / Leith A.J. ~llis, ESQUIRE Attorney I.~. No. 53229 RULE TO THE PLAINTIFFS: You are hereby ordered and directed to file your Complaint against Defendants, Sambhu N. Kundu, M.D. and George E. Jefferies, III, M.D., in the above-captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non pros. Date:~L ~7 2~ TRUE COi Y FROM RECORD Prothonotary, Cumbe~l~ County CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing RULE was served upon counsel of record this day of November, 2001, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee A//derson, Esquire Smigel Anderson & Sacks 2917 N~ Front Street Harrisburg, PA 17110 By: FOULKROD ELLIS PROFESSIONAL CORPORATION Amy L. 'K.nou~e,~Paralegal ~ERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE TO FILE CERTIFICATE OF SERVICE was served upon counsel of record this /~ day of November, 2001, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harrisburg, PA 17110 By: FOULKROD ELLIS PROFESSIONAL CORPORATION Amy L. Knouse~ Paralegal FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 Fax: (717) 213-4202 JANET L. PRAVE AND : NICK THOMAS PRAVE : : Plaintiffs : SAMBHU KUNDU, M. D. AND : GEORGE E. JEFFERIES, III, M.D.: Defendants : Attorneys for Defendants: Sambhu Kundu, M.D. and Gsorae E. Jeffries. III, M.D.. P.C. IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 JURY TRIAL DEMANDED PP~AECIPE TO FILE A CERTIFICATE OF SERVICE TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Kindly file of record the attached Certificate of Service of the notice of entry of judgment. Respectfully Submitted, By: FOULKROD ELLIS PROFESSIONAL CORPORATION No. 85651 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing notice of entry of judgment was served upon counsel of record this 27th day of February, 2002, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harrisburg, PA 17110 By: FOULKROD ELLIS PROFESSIONAL CORPOP~A~ION Beth E. Forbes, ~aralegal ¢ CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PP~AECIPE TO FILE A CERTIFICATE OF SERVICE was served upon counsel of record this 27th day of February, 2002, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harrisburg, PA 17110 By: FOULKROD ELLIS PROFESSIONAL CORPO N~ Beth E. F6rbes, Pa~alegal FOULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 Fax; (717) 213-4202 JANET L. PP~AVE AND NICK THOMAS PP~AVE Plaintiffs Vo SAMBHU KUNDU, M.D. AND GEORGE E. JEFFERIES, III, Defendants M.D. Attorneys for Defendants: San~bhu Kundu, M.D. and Georne E. Jeffries. III. M.D.. P.C. IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 : JURY TRIAL DEMANDED PRAECIPE TO FILE A CERTIFICATE OF SERVICE TO: PROTHONOTARY OF CUMBERLAND COUNTY, PENNSYLVANIA Kindly file of record the attached Certificate of Service of the Praecipe to Enter Judgment Non Pros. Date: ~ III0~ By: Respectfully submitted, FOULKROD ELLIS PROFESSIONAL CORPORATION CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE TO ENTER JUDGMENT NON PROS was served upon counsel of record this 11th day of MARCH, 2002, by depositing said copy in the United States Mail at Harrisburg, Pennsylvania, postage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N. Front Street Harr±sburg, PA 17110 By: FOUI.KROD ELLIS PROFESSIONAL CORPORATION Be~c~ E~. Forbes, [ Parale-gal CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing PRAECIPE TO FILE CERTIFI~TE OF SERVICE OF THE PRAECIPE TO E~ER J~G~ NON PROS was se~ed upon counsel of record this 11th day of March, 2002, by depositing said copy in the United States ~il at Harrisburg, Pennsylvania, postage prepaid, first class deliver, and addressed as follows: C. Lee ~derson, Esquire Smigel ~derson & Sacks 2917 N. Front Street Harrisburg, PA 17110 FOULKROD ELLIS PROFESSION~ CORPO~TION By: ' ~ ~ ' BeE~~Fo~bes,~ FoULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 Fax: ~ 213-4202 JANET L. PRAVE AND NICK THOMAS PRAVE Plaintiffs Ve SAMBHU KUNDU, M.D. AND : GEORGE E. JEFFERIES, III, M.D.: : D e f endant s : Attorneys for Defendants: Sambhu Kundu, M.D. and ~j~9~i I~_~_M. D. ,_ P- C. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 JURY TRIAL DEMANDED PRAECIPE TO ENTER JUDG~TNON PRO~ TO THE PROTHONOTARY: Kindly enter judgment Non Pros in favor of Defendants, sambhu N. Kundu, M.D. and George E. jefferies, III, M.D. and against Plaintiffs, Janet L. Prave and Nick Thomas Prave, for Plaintiffs' failure to file a Complaint pursuant to a Rule to File Complaint entered on October 17, 2001 (Exhibit "A") and Notice of Entry of Judgment provided in accordance with Pa.R.C.P. 237.1 on February 27, 2002 (Exhibit "B"). FOULKROD ELLIS PROFESSIONAL CORPORATION -- / I 651 FOIILKROD ~LLIS professional Corpora=ion 1800 Lingles=own Rd., suite 305 ~{arrisbur~, PA 17110 Telephone: (717) 213-%200 JANET L. PRAVE AND NICK THOMAS PRAVE Plaintiffs SAMBHU KUNDU, M.D. AND GEORGE E. JEFFERIES, Defendants III, M.D.: : : AttorneyS for Defendants: Sambhu KundU, M.D. and r' s D iN THE COURT OF COMMON PLEA~ CUMBE~ COUNTY, pENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 JU~Y TRIAL DEMANDED PRAECIPE FOR RULE TO FILE COMPLAINT TO: pROTHONOTA~Y OF CUMBERLAND COUNTY, pENNSYLVANIA Please is~uea Rule upon Plaintiffs to file a Complaint within twenty (20) days from service hereof or suffer judgment no___~nrp_r_9~. FOULK~OD ELLIS Attorney I.~. No. 53229 RULE TO THE PLAINTIFFS: You are hereby ordered and directed to file your Complaint against Defendants, Sambhu N. Kundu, M.D. and George E. jefferies, Iii, M.D., in the above.captioned matter within twenty (20) days of service of this Rule against you or suffer judgment non rp_~Q~. ~rotho~otary, Cumbe~l~ CourtLy C~___~TIFICATE OF SERVIC~ I HEREBY CERTIFY that a true and correct copy of the foregoing RULE was served upon counsel of record this _ day of November, 2001, by depositing said copy in the united States Mail at Harrisburg, Pennsylvania, P°stage prepaid, first class delivery, and addressed as follows: C. Lee Anderson, Esquire smigel Anderson & Sacks 2917 N~ Front Street Harrisburg, PA 17110 FOULKROD ELLIS pROFESSIONAL CORPORATION By: S. WALTER FoULKROD, III, ESQUIRE Pa. Supreme Court I.D. No. 01982 LEIGH A.J. ELLIS, ESQUIRE Pa. Supreme Court I.D. No. 53229 ANDREW H. FoULKROD, ESQUIRE Pa..gupreme court I.D. No. 77394 FoULKROD ELLIS Professional Corporation 1800 Linglestown Rd., Suite 305 Harrisburg, PA 17110 Telephone: (717) 213-4200 JANET L. pPd%VE AND : NICK THOMAS PRAVE : Plaintiffs : : : : V. : Attorneys for Defendants: Sambhu Kundu, M.D. and G~ E._ Je~~=-~' ~P ' C~' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, pENNSYLVANIA CIVIL ACTION LAW NO. 01-5612 SAMBHU KUNDU, M.D. AND : GEORGE E. JEFFERIES, III, M.D.: : Defendants : JURY TRIAL DEMANDED TO: Janet L. prave and Nick Thomas Prave C/0 C. Lee Anderson, Esquire Smigel Anderson & Sacks 2917 N Front street Harrisburg, PA 17110 DATE OF NOTICE: February 27, 2002 iMPORT.A~TNOTICE O_F-ENTRY OF ju~u~-- YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO FILE A COMPLAINT 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 RIGHT TO SUE THE DEFENDANTS AND THEREBY LOSE PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. 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. MidPenn Legal services 8 irvine Row carlisle, PA 17103 (717) 232-0581 Date FOULKROD ELLIS coRpORATION By: ~~~l~ire 85651 Att~ I HEREBY CERTIFY that a true and correct copy o~ the Eoregoing notice of entrY of jud~ent was served upon counsel of record this 27th day o~ FebruarY, 2002, by depositing said copy in the united states Mail at Harrisburg' pennsylvania, postage prepaid, first claSS deliverY, and addressed as follOWS: Esquire C. Lee Anderson, & Sacks smigel Anderson 2917 N. Front street Harrisburg' FA 17110 By: I HEREBY CERTIFY that a true and correct copy of the foregoing pRAECIPE TO ENTER jUDGMENT NON pROS was served upon counsel of record this 11th day of MARCH, 2002, by depositing said copy in the united states Mail at Harrisburg, pennsylvania, postage prepaid, first claSS delivery, and addressed as follOWS: Esquire C. Lee AndersOn, & Sacks smigel Anderson 2917 N. Front street Harrisburg, PA 17110 By: FOUI~KROD ELLIS PROFESSIONAL CoRPORATiON