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HomeMy WebLinkAbout09-5804... - r Y I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Credigy Receivables, Inc CIVIL DIVISION Plaintiff oq- s8o? Civ?ITe?-m vs. NO: 2000-08800 HEATHER E MERRIS 1871 W Lisburn Rd Carlisle PA 17013 Defendant PRAECIPE FOR WRIT OF REVIVAL TO THE PROTHONOTARY: Please issue writ of revival of lien of judgment entered at this Court at 2000-08800 and enter it in the judgment index against HEATHER E MERRIS in the amount of $9,673.72 with interest from December 27, 2000. Edwin AKbrahamsen & Associates, P.C. Michael F. Ratchford, Attorney I.D. No.: 86: Attorney for Plainti f, Rl.ED--t`..TfCE OF THE PRM? )'T)TARY 2009 AUG 24 AID 8: 32 NIA 4a9.oo Po AT-N 37.421 GBF Q•00 00 0 f a9. 4a - Pb Arry *2-oo bue.Co c? 3E0 P-T aa9(. 5 o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Credigy Receivables, Inc vs. Plaintiff : CIVIL DIVISION 0Q _ 5g CA Ciy i I Terns NO: 2000-08800 HEATHER E MERRIS 1871 W Lisburn Rd Carlisle PA 17013 WRIT OF REVIVAL To HEATHER E MERRIS Defendant : (1) You are notified that the plaintiff has commenced a proceeding to revive the lien of the judgment entered at the Court of Common Pleas of CUMBERLAND County at Judgment Number 2000-08800. (2) The plaintiff claims that the amount due and unpaid is $9,673.72 with interest from December 27, 2000. (3) You are required within twenty days after service of this writ to file an answer or otherwise plead to this writ. If you fail to do so, a judgment of revival in the amount claimed by the plaintiff may be entered without a hearing and you may lose your property or other important rights. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. (),oaf- : $ /a 9.0 Pb ATtY a, oo 6UE co Date: MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 4-jz 92M d"I me of Pro o ary r Clerk By Deputy WRIT OF EXECUTION and/or ATTACHMENT COMN[ONWF.ALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5804 Civil CIVIL ACTION - LA W "tO THE SFiER1FF C-F CUMBERLAND COUNTY: "I'o satisfy the de'~~t, interest and costs due CLAIMS RECOVERY SYSTEMS, ASSIGNEE OF F1RST SELECT, INC. Plaintiff (s) From HEATHER MERRIS, 1607 GRAY DRIVE MECHANICSBURG, PA 17055 (1 i You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY UPON ANY AND ALL PERSONAL PROPERTY, INCLUDING VEHICLE LISTED ON ENCLOSED REPORT, LOCATED AT 1607 GRAY DRIVE MECHANICSBURG, PA 17055 . (2) You are. also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: 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; {; ~~ 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. Amoum~: Ihie $9,673.72 (merest $6,489.61 Attv's Comm °~o Attu Paid $2.50 Plaintiti' }'aid $181.42 Date: C-ctober 26, 2f~12 ~se~~.i~ L.L. $$.50 Due Prothy $2.25 Other Costs ~_~S ~5~~~~1 David Buell, Prothonotary By: _ l~. ~T ~ Deputy RE(~UEST:NC, PARTY: Name :NICHOLAS BOTLA, ESQUIRE Address: C'/O CRS, P.O. BOX 703 CARNEGIE, PA 15106 Attorney tor: PLFF Telephone: 1-800-219-8603 Supreme Court ID No 307542 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI" CML DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: ^ Confessed Judgment .°= f , 1. ~, (--' ~~-~ (,~ k ~~Il' ~ ~ ~ S TO 'I`HE PROTHONOTARY OF THE SAID COURT: :"~ .;1~ :" -. rte; r ^ Other File No, ~~ U(C7 - `;~~ ~~~~ --.._.._.-- Amount: Due!!~~ Jj ~. '~ ~ ---.-_-_-- Interest ~ ~o t~ , ,(~ - ~ ~ __._J _- Atty's Comm ~-!~ _.__- ,~ Costs _ ~ ~ ~ ~ } ` _._.--_ The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, 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 puusuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of CC~I+~lX'Y ~ ~ 1(C~. ._.____ County, for debt, interest and costs, upon the following described property of the: defendant (s) ~lt P ''U l~ ~L1C~_~~~ -~)('I~C~1G~~ ~'I~ ~f~~C~~UC1~f-J~-- v~~~1~~~~% I+-`~-F~~i C~ii r~i(~ ~~.rF~a ~rJa, 7. la~'`(~~rc~ C~~ Ih.(3'~ ~-~,~~~.~ - ~-,--- ~ ~U t~ ,r~~C'~r~r t, c~~hu r~~ ~'~~ _1 PRAECIPE FOR ATTACHMEN'C EXECUTION Issue writ of attachment to the Sheriff of 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 listl and all other property of the defendant(s) in the possession, custody or control o:f the said garnishee(s). ^ (Indicate) Index this writ against the garnishee (s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. (~ Date ___~~ ;~ Signature: ~- `'~-' Print Name: !~ ~ (~10 (G-i ~ (,~ { _ S - n~~~ ~ a~- ~ ~ ~ Address; '~~ :, C ~ S J_~ (~_ ~~~~ `l(~~s `a~ , ~;(T> t~ ~ ~ Attorney for: ~ r iS eCUt,'<C ~. -1t~' 1S i, << ~ C--~ . ~.~ Telephotle: (- ~UQ ~_. ~ 1 `~ ~ ~~~,:~~'.:~ ~`, G:~ ~ `` `' ~ Supreme: Court ID No: ~~) ~ ~ ~{,.-~ Y~p~ aa?a~at~~a~P ~ a e ~v ~y ~~ ~~ ~ ~x T~~ IN THE COURT OF COMMON PLEAS OF ~r,~lt-~~'V ~C{/ C.'~ COUNTY, PENNSYLVANIA AFFIDAVI l OF NON-MILITARY SERVICE The undersigned, being duly sworn, according to law, deposes and says that the DefendantSs) is!are not in the Military or Naval Service of the United States ox its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; That ~~r'-'C~-~li~`r i~~r f ' S is over years of gage and is employed and residesa.t (G~(~~~ (,rd~.r`~V~v." ~t'~~~(~Vi~('SfaUf,~ ld,~ l`~(i~i~ I,~~i ~;~~! ~tfG~ hereby verify that I am ~~{(UI ~. I~` i.~ for Plaintiff, that I am fully authorized to make this Verifications on their behalf, that the Defendants are unavailable to make this \/erification, that. the facts contained in the foregoing pleading are true avid correct to the best of my knowledge, information and belief, and the source of my information are interviews with my client and the Plaintiff's filed documents. 'ihe verifier understands that false statements herein are made subject to the penalties of 1 S Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ri ,.. . Signed: ` ~_ Dated: tC,) ~ I ~ ~ c~ IN THE COURT (JF COMMON PLEAS OF CUMBERLAND COL.INTY PRAECIPE FOR ENTRY OF APPEARANCE ..~ __ _, ;•.~ _. _._ CLAIMS RECOVER')' SYSTEMS, `_ ~~' _ Assignee of First Select, Inc., -~ `^ : ~'~ Plaintiff, Docket No. 2009-5804 vs. HEATHER MERRIS, Defendant. To the Prothonotary: Kindly enter my appearance on behalf of Plaintiff, Claims Recovery Systems, Assignee of First Select, Inc., on the above matter. Respectfully submitted: Date Nic olas Botta, Esquire Attorney for Plaintiff I.D. #307542 Claims Recovery Systems 6 East Main Street P.O. Box 703 Carnegie, PA 15~ 106 1-800-219-8603 IN 'I'HF. COURT OF C01vIMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIRST SELECT. INC. Plaintiff vs. HEATHER MERRIS Defendants}, As authorized representati~~e of Credigy Receivables, Inc., I hereby certify that the original judgment creditor and assignor, FIRST SELECT, INC., whose address is 3715 Davinci t.`ourt, Suite 200, Norcross, GA 30092, sold, transferred and assigned to Claims Recovery Systems, P.O. Box 703, Carnegie, PA 15106, all title, right and interest in the judgment entered on 2/14/2001 in the Commonwealth of Pennsylvania, Case No. 2009-5804, filed in the County of CUMBERLAND, against Defendant and judgment debtor, HEATHER MERRIS, whose last known address is 1871 W Lisburn Rd, Carlisle, PA, 170130000, and further warrant that the amount of $9673.72 is unpaid, due and owing, plus court costs and interesl. accrued from the date of judgment to the date of satisfaction. Witness my si mature this the ~~~~~ da of June 2012 b Y -' .~~ (/ . Jascxi S. Williams, Vice President of Credigy Receivables, Inc., a Nevada ~eorporation ("CRY'), attorney-in- fact pursuant to Power f Attorney, dated as of 7/30/2004, ranted by ~st Select, Inc., a D aware Corporation, in favo3~e#~-~.I; ropy of which is attached. as Exhibit A hereto. ~~ sod ~~~ STATE OF GEORGIA § ~~`~~ ~ aC7~f~Uc7~~~ a~ § ~~ COUNTY OF GWINNI=;TT § '+~~ ~a~S~ This instrument was acknowledged before me, by Jason S. Williams, Vice Pm-esid~ ohs r ~ . Credigy Receivables, Inc., on this date. Given under my hand and seal of office on the ~ '. day of June, 2012. J~i _ h ~'~ j ~ ~` ~~`- NOTARY ]PUBL ~ -STATE OF GE~_~R~IA~,.. ~~, :~~, ~~ .~.; ,- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson [ ii ",f— t 4 L E .J1 Sheriff ,- fit l��I�rt;<t�„ .� ,t H Jody S Smith ` Chief Deputy 2tl13 AUG -S Ph Richard W Stewart "`{ " Solicitor s =4,F ME V4EF-OF-- CUMBERLAND COUNIT i PEN SYLVA,N1A Claims Recovery Systems Inc. vs. Case Number Heather Merris 2009-5804 SHERIFF'S RETURN OF SERVICE 11/14/2012 08:55 PM-Ryan Burgett, Deputy, being duly sworn according to law, states that on November 14, 2012 at 8:55 PM hours, served the requested Writ of Execution and Claim for Exemption Form by"personally" handing a true and attested copy to a person representing themselves to be the Defendant,to wit: Heather Merris AKA Heather Auxt at 1607 Gray Drive, Upper Allen Township, Mechanicsburg, PA 17055, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on November 15, 2012, 12/20/2012 02:44 PM- Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Sheriffs Sale Bill in the above titled action, upon the property located at 1607 Gray Drive, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. NOTE: Copy of sale bill NOT mailed out to atty's office- I received a fax at 1547 hours the same date it was posted requesting to put the matter on"hold". 12/21/2012 Property sale scheduled for 01-10-13 cancelled at request of plaintiffs attorney-defendant entered into payment arrangement. 08/05/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. Plaintiffs attorney collected$ 3,700.00 from defendant. SHERIFF COST: $180.21 SO ANSWERS, August 05, 2013 RONi 'R ANDERSON, SHERIFF (c)CountvSuite Sheriff,Toleosof.Inc.