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HomeMy WebLinkAbout07-369307- 3~4 3 C ivy I IN THE COURT OF COMMON PLEAS Term CUMBERLAND COUNTY, PENNSYLVANIA William Warren Enola Drive Enola, PA 17025 Portfolio Recovery Assoc. LLC. Kisha L. Cox, debt collector P.O. Box 12914 Norfolk, VA 23541 Plaintiff(s) & Addresses Defendant~,~& Addresses PRAECIPE FOR WRIT OF SUMMONS TO THE PROTHONOTARY OF SAID COURT: Please issue writ of summons in the above-captioned action. Writ of Summons shall be issued and forwarded to (X) Attorney ()Sheriff. Deanna Lynn Saracco, Esquire 76 Greenmont Drive Enola, Pennsylvania 17025 Phone 717-732-3750 SaraccoLaw@aol.com ~ J~-.. Signature of Attorney Dated: 5/20/07 WRIT OF SUMMONS TO THE ABOVE NAMED DEFENDANT(S): YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION AGAINST YOU. n P thonotary Dated: 020 BY~ putt' C:} ~ c:3 ~ C~. r ~'^,, "'~ ~ ~~ ~~~" ~~ ~ z-r~ ~ /. ~ r~ ~ ~ ' ' ~ p b _ ,,. . 1 _ - y~ cti~ _ _; ~ - - C.,,3 -~~ ~.:. 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA William Warren, Plaintiff, Civil Action No.: 07-3693 v. Portfolio Recovery Assoc., LLC and Kisha L. Cox, debt collector, Defendants. Jury Trial Demanded IMPORTANT NOTICE TO: Christopher D. Lagow, Counsel Portfolio Recovery & Assoc., Inc. 140 Corporate Blvd. Norfolk, VA 23502 DATE OF NOTICE: JULY 30.2007 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10, Dl AYS FROM THE DATE OF THIS N OTICE, A JUDGEMENT 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 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 717-249-3166 800-990-9108 /s/De acco Deanna Lynn Saracco 76 Greenmont Drive Enola, PA 17025 (717) 732-3750 Attorney for Plaintiff G - ~ ~ vt ~ I~, ~; , s" 2 ~;. ~ +C~ ~ •-- ~ ~ ~ ~ ~ d IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA William Warren, Plaintiff, v. Civil Action No.: 07-3693 Jury Trial Demanded Portfolio Recovery Assoc., LLC and Kisha L. Cox, debt collector, Defendants. ~ AF~IPE ~ D~ISC.U..~TT~Ni~E/WITIII)~ WITR PREJUDICE And now comes Plaintiff, by and through her counsel, Deanna Lynn Saracco, and files this Praecipe to Withdraw the above captioned matter, with prejudice as the parties have amicably settled their dispute. This case should be discontinued and you may mark this case CLOSED. Respectfully submitted, F Dated: ~ ~ c~,Q Deanna Lynn Saracco, Attorney for Plaintiff 76 Greenmont Drive Enola, PA 17025 717-732-3750 ~,erti$cate of Serv'ce: I hereby certify that I served, via hand delivery, a copy of the forgoing, on the defendant as follows: Edwin R. Cummings, Esquire Sessions Fishman Nathan LLP 1000 Skokie Blvd., Suite 480 Wilmette, IL 60091 Dated: ~ ~ t f ~07 Deanna Lynn Saracco ... ~' GO