HomeMy WebLinkAbout09-5804... - r
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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
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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.