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HomeMy WebLinkAbout10-3640IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff CIVIL ACTION-LAW VS. AMY BROUNAVELL, : DOCKET NO.: 16 - 3` qd ?]- Defendant I PRAECIPE TO ENTER JUDGMENT To the Prothonotary: Kindly enter judgment in this matter against the Defendant, Amy Brounavell, in the amount of $6,616.53. 0 C s T 1 r C Fri M Respectfully Submitted, %- c r r ' THE REMIT CORPORATION .. LAT-JAIRIA T. V L R, ESQUIRE Attorney ID 827-K6 The Remit Corporation 36 W Main St PO Box 7 Bloomsburg, PA 17815 Telephone 570-387-1873 Fax 570-387-6474 sqa7. a - r 11 s e it--&- zgsk{ COMMONWEALTH OF PENNSYLVANIA rnl INTY C)F• CUMBERLAND Mag. Dist. No.: 09-2-02 MDJ Name: Hon. JESSICA BRENBAKER Address: 1 COURTHOUSE SQ E WING CARLISLE, PA Telephone: (717 ) 240-6564 17013 REMIT CORPORATION 36 W. !LAIN ST BLOOMSBURG, PA 17815 THIS IS TO NOTIFY YOU THAT: NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRE rREKIT CORPORATION, O 36 N. MAIN ST BLOOMSBURG, PA 1 L V DEFENDANT: ME and ADDR `k (- - V' BROUNAVELL, AMY pp,,?('. -' 413 N. PITT ST APT/STE 5 CARLISLE, PA 17013 L J Docket No.: CV-0000150-07 Date Filed: 4/11/07 Judgment: FOR PLAINTIFF (Date of Judgment) 5/21/07 Judgment was entered for: (Name) REMIT CORPORATION, ® Judgment was entered against: (Name) BROUNAVELL, ANY 11 in the amount of $ 61 616.5 Defendants are jointly and severally liable. Damages will be assessed on Date & Time ? This case dismissed without prejudice. ? Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ Total $ 6,616.53 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ I ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date , Magisterial District Judge certify that this is a tru Erect copy of'the record of the proceedings containing the judgment. O Date Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-06 DATE PRINTED: 5/22/07 7:50:00 AIL BLED-ur ?' (:E T c r Pp r,"T.;i i4RY G H;.:,;.. r 2010 JUN -3 AM 11: 4! CUMB&'I',A LJ ODUNTY PENNSYNA#WA COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND - - - 09-2-02 DJ Name: Hon. Jessica E Brewbaker Address: 1 Court House Square, East Wing Carlisle, PA 17013 Telephone: 717/240-6564 AMOUNT FILING COSTS $__LLE_ 50 POSTAGE $ SE RVICE COSTS $ a ej. 7 S CONSTABLE ED. $ S.O0 TOTAL 145.28 DATE PAID CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS Remit Corporation 36 West Main Street Bloomsburg, PA 17815 800-326-9962 VS. DEFENDANT: NAME and ADDRESS Amy Brounavell 413 N Pitt Street Apt 5 Carlisle, PA 17013 Docket No.: CV-150-07 AIL Date Filed: 4/11/07 Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 6,471.25 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): Plaintiff is seeking payment for unpaid Classic visa credit card services provided by Citibank (South Dakota) National Association. This account has been purchased by Unifund CCR Partners and assigned to Remit Corporation. The principal balance on this account is $3,034.30 and interest has accrued in the amount of $2,678.37 at the rate of 19.99%. The last payment on this account was received on or about 04/22/2003. Plaintiff is seeking attorney's fees in the amount of $758.58 based on 25% of the principal balance. Plaintiff is requesting judgment in the amount of $6,471.25 plus court costs. 1, Laurinda J Voelcker verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unswom ifi 'o au rities. (Signature ?IgLntff or uthonzed Agent) Plaintiffs Attorney: Address: Telephone: IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within district justice jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 308A-05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff CIVIL ACTION-LAW VS. AMY BROUNAVELL, DOCKET NO.: Defendant AFFIDAVIT OF NON-MILITARY SERVICE The Defendant is not now in the Military Service, as defined in the Soldier's and Sailor's Civil Relief Act of 1940 with amendments not has been in such service within thirty days hereof. 2? Al Dated this day of , 2010 Laurinda J. Voelcvr, Esquire Attorney For Remit Corporation Attorney ID 82706 36 West Main Street Bloomsburg, PA 17815 Tel.(570) 387-1873 Fax(570)387-6474 Request for Military Status Department of Defense Manpower Data Center 10 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 May-12-2010 11:37:13 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Based on the information you have furnished, the DMDC does not BROUNAVELL AMY possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 05/12/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:45E1AOOG8A https://www.dmdc.osd.mil/appj/scra/popreport.do 05/12/2010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff CIVIL ACTION-LAW VS. AMY BROUNAVELL, DOCKET NO.: Defendant CERTIFICATION OF ADDRESSES I certify that the precise address(es) of Plaintiff and Defendant(s) are as follows: Plaintiff: Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Defendant: Amy Brounavell 413 North Pitt Street Apt. 5 Carlisle, PA 17013 Respectfully submitted, - -/Zftdk Laurinda J. Voelcker, Esquire PA ID #82706 Remit Corporation 36 West Main Street Bloomsburg, PA 17815 Tel(570)387-1873 Fax(570)387-6474 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION, Plaintiff CIVIL ACTION-LAW VS. AMY BROUNAVELL, DOCKET NO.: Defendant NOTICE OF ENTRY OF JUDGMENT ( ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of $6,616.53 on May 21, 2007. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are enclosed. r ?4w Pro onotary Civil Di f. By: If you have any questions regarding this Notice, please contact the filing party: NAME: Remit Corporation ADDRESS: 36 West Main Street Bloomsburg, PA 17815 TELEPHONE NO: 570-387-1873 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: NAME: Amy Brounavell 413 North Pitt Street Apt. 5 Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff . CIVIL ACTION -LAW C ~ a NO. 10-3640 r:s i.' d== ~~- ` F flies AMY BROUNAVELL ~'' ~"` ~ c~, ~" ~' ; Defendant _ `_ .,., ~ _~_ PRAECIPE TO MARK JUDGMENT TO USE OF ASSIGNEE L-' ~ ~ w '`.' f.~ =-i ' r7 - ~- ems. TO: PROTHONOTARY: Please mark the Judgment entered in the above captioned case against the Defendant(s), AMY BROUNAVELL, to and for the use of Unifund Corporation, Assignee, as per Assignment of Judgment, a copy of which is attached hereto and made a part hereof as Exhibit A. DATED: CJ ~ BY: Laurinda J. Vo er, emit Corporation JUDGMENT MARKED TO USE OF ASSIGNEE AND NOW, to wit, this ~G day of , ~A~G , the Judgment entered in the above captioned case against the Defendant (s), AMY BROUNAVELL, is hereby marked to and for the use of Unifund Corporation. Prothonotai t ~YQ4 ~ f~f~ ~ x-~ 3 ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA REMIT CORPORATION Plaintiff VS. AMY BROUNAVELL Defendant CIVIL ACTION -LAW NO. 10-3640 ASSIGNMENT OF JUDGMENT KNOW ALL MEN BY THESE PRESENTS, that Remit Corporation in consideration of the prior contractual agreement between the parties, the receipt and sufficiency of which is acknowledged, does hereby grant, bargain, transfer, assign and make over to Unifund Corporation of 10625 Techwoods Cr, Cincinnati, Hamilton County, Ohio, 45242 (hereinafter "Unifund"), its successors and assigns, a certain Judgment recovered by Remit Corporation of 36 West Main St, Bloomsburg, Columbia County, Pennsylvania 17815, in the Cumberland Court of Common Pleas, Cumberland County, Pennsylvania, filed to docket number 10-3640 against Defendant, AMY BROUNAVELL, for the sum of $6,616.53 which constitutes damages and costs of suit, plus interest at 6.00% annum from 06/03/2010, together with all the benefits and advantages that may be obtained thereby, and full power to enforce and recover the Judgment to Unifund's own use. Remit Corporation, further authorizes and Empowers the Prothonotary or any attorney on behalf of the Assignee to mark said Judgment to the Assignee's use. IN WITNESS WHEREOF and intending to be legally bound hereby, Remit Corporyat~ion, has executed this As~si~gn®ment this i ` day of ~~~ %"~.._~..2010. Laurinda J. elcker General Counsel Remit Corporation SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson L Sheriff j:X a _ Jody S Smith 4lrrrt} Of trynLrr( 0 ? 01 C= -r Chief Deputy Richard W Stewart Solicitor OFF r T -r -,R,FF -• y T ;Z Unifund Corporation vs. Amy Brownawell Case Number 2010-3640 SHERIFF'S RETURN OF SERVICE 06/10/2011 02:34 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1434 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Amy Brownawell, in the hands, possession, or control of the within named garnishee, Cornerstone Federal Credit Union, 5 Eastgate Drive, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lindsey Milled, Financial Service Representative personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 15, 2011 to Amy Brownawell, 413 N Pitt Street, Apartment 5, Carlisle, PA 17013. SO ANSWERS, June 15, 2011 RON R ANDERSON, SHERIFF ?-X- Tim'Back, Deputy n; {,qu•,•yJU.ar ?ienfT T'rl6s'ofl. Irn;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA UNIFUND CORPORATION, Plaintiff vs. AMY BROUNAVELL, Defendant vs. CORNERSTONE FCU, Garnishee c irrnn CIVIL - LAW z DOCKET NO. 10-3640 CIV? PRAECIPE TO DISCONTINUE ATTACHMENT To the Prothonotary: FCU. Kindly Discontinue the Attachment of the Defendant's bank account with Cornerstone SUBMITTED BY: Lauifnda VoeiAer, PA ID# 82706 Attorney for Plaintiff 36 West Main Street Bloomsburg, PA 17815 Telephone: (570)387-1873 Fax: (570)387-6474 4 C, -M+ MF ? rrj o C' sC? z r? o M, 014 &8•"?Pd al? I Ck,?t? S 170 p-4 a(Rfle1 WRIT OF EXECUTION and/or A--AC'7MENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) O 10-3640 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due UNIFUND CORPORATION, Plaintiff (s) From AMY BROUNAVELL, 413 North Pitt Street, Apt 5, Carlisle, PA 17013 (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 evied upon in the possession of GARNISHEE(S) as follows: CORNERSTONE FCU, 5 East Gate Drive, Carlisle, PA 17015 and to notify the garnishee(s) that: (a) an attachment has been issued; (l:) 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; (3) 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. Amount Due $6,616.53 Interest from 6/3/10 -- $388.29 Arty's Comm % Atty Paid $62.25 Plaintiff Paid Date: 6/3/11 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $2.00 Other Costs 7?- David D. Buell, Prothonotary By: Deputy Name LAURINDA J. VOELCKER, ESQUIRE Address: 36 WEST MAIN STREET BLOOMSBURG, PA 17815 Attorney for: PLAINTIFFS Telephone: 570-387-1873 Supreme Court ID No. 82706 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand and the seal of said Coyrt at Carlisle, Pa 3rd \tz P t? Prothonotary L SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r Sheriff Jody S Smith4 Chief Deputy -; e Richard W Stewart Solicitor `i ?D,VSYL?'ANIA Unifund Corporation Case Number vs. Amy Brownawell 2010-3640 SHERIFF'S RETURN OF SERVICE 06/10/2011 02:34 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on June 10, 2011 at 1434 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Amy Brownawell, in the hands, possession, or control of the within named garnishee, Cornerstone Federal Credit Union, 5 Eastgate Drive, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Lindsey Milled, Financial Service Representative personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on June 15, 2011 to Amy Brownawell, 413 N Pitt Street, Apartment 5, Carlisle, PA 17013. 01/23/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $8811 SO ANSWERS, January 23, 2012 RON r R ANDERSON, SHERIFF Collr. 11 ;ner. f I e: .,SUfl I'i<,