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Home My WebLink About10-4265SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~a~~xtr o~ ~~i~t~6rr>>~D 4~F F7C'~ y~F Fns cy~RIF~' F!tF~ ,~:, ~: F: i_,, i.,:_ ~ .. 201QJ:,~ -2 r~;~ ~~ 4$ Ford Motor Credit Company vs. Case Number Paul C. Yesavage 2010-4265 SHERIFF'S RETURN OF SERVICE 07/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Paul C. Yesavage, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Paul C. Yesavage. Current resident of 468 Centerville Road, Newville, PA 17241 advised Deputies, Paul C. Yesavage was previous tenant from over one year ago. The Newville Postmaster has confirmed, Paul C. Yesavage now receives his mail at P.O. BOX 725, Foxworth, MS 39483. SHERIFF COST: $43.80 July 01, 2010 SO ANSWERS, ' RON R ANDERSON, SHERIFF (c1 CountySuite Shenff. Teleosoft. Inc. r fILC~~~ _ - ~::~ Attorneys for P1ai~Iif,~~~~ ESIUU ` ` 2~ ~'I'; I~~ ~:~ G~.~P,~~~ - ~ ~~TY MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 Charlene A. Taylor, Esq. Identification No. 85248 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (L15) ~/ISy-/1JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. PAUL C YESAVAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. l(~ - 7 Z 6 5 Defendant(s). PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, for that of the verification previously filed. Date: June 15, 2010 Respectfully submitted, MAURICE $~'NEEDLEMAN, P.C. CHARLENE~. TAYLOR, ESQ Attorney for Plaintiff CERTIFICATE OF SERVICE I, Charlene A. Taylor, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Substitute Verification on behalf of FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, to be served by regular, first class mail, postage pre-paid upon: PAUL C YESAVAGE 468 Centerville Rd Newville, Pa 17241-9465 Respectfully bmit ed, MAURICE ~ MAN, P.C. BY: Charlene A. Taylor, E Attorney for Plaintiff DATED: June 15, 2010 VERIFICATION I, ~ verify that I am the Authorized Representative for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company, and are duly authorized to take this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Representative of Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company DATE: `~lS~vl~ PAUL C YESAVAGE Our file no. 11411 48053000000043925018 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff, V. PAUL C YESAVAGE Defendant(s). Attorneys for Plaintiff Our File: 11411 CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 10-4265 PRAECIPE TO REINSTATE TO THE PROTHONOTARY: ;? .? ?? r- _ amt C"D "f Y 4 ` 2-' ? ,c_ C] n M1 _ c.., ':j Kindly reinstate the attached Complaint originally filed with the Court on June 28, 2010. MAURICE & NEEDLEMAN, P.C. Date: April 4, 2011 BY: Jo Needleman, Esq Attorney for Plaintiff QU4 810.00 Pd a CERTIFICATE OF SERVICE I, JOANN NEEDLEMAN, ESQUIRE, do hereby certify that I have caused a true and correct copy of Plaintiff's Praecipe to Reinstate Complaint to be served by United States 1" Class mail, postage prepaid upon the following: PAUL C YESAVAGE 323 S. PITT ST CARLISLE, PA 17013-3817 MAURIC?-kNEEDLEMAN, P.C. BY: eedleman, Esquire Date: April 4, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff cr p#?rtkGFrb OFF) G - RIFF P'17"fro t; Jody S Smith Chief Deputy Richard W Stewart Solicitor ql 25 PM i Ford Motor Credit Company Case Number vs. Paul C. Yesavage 2010-4265 SHERIFF'S RETURN OF SERVICE 04/19/2011 03:45 PM - Jody Smith, Chief Deputy, who being duly sworn according to law, states that on April 19, 2011 at 1545 hours,she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paul C. Yesavage, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. '4CG JODY S. SMITH, DEPUTY SHERIFF COST: $40.00 April 20, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF ,r) CoultyJulte S`enff Te eosoft . In;;, MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 (215) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE Defendant(s) Attorneys for Plaintiff CUMBERLAND COUNTY COURT COMMON PLEAS CASE NO. 10-4265 PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Cl) C -n -v co --r rn -n c o z? ma z N w C, 0 p? o x oC-) " r A w No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, PAUL C YESAVAGE in the amount as follows: Principal Amount $ 21380.71 Interest to Date $ 7612.70 Costs $ 185.80 TOTAL $ 29179.22 Date: June 1, 2011 MAURICE & N DLEMAN, P.C. BY: JO EEDLEMAN, ESQ. Attornev for Plaintiff OUMv %14 00 a I MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 1J172S9-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4265 AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 05118/2011 she mailed a written Notice of Intention to File the Praecipe to Defendant, PAUL C YESAVAGE , at 323 S. PITT ST , CARLISLE, PA 17013-3817 by regular mail. MAURICE & EDLEMAN, P.C. BY: TJOAN1W NEEDLEMAN, ESQ. Attorney for Plaintiff SWORN TO A%Kaa UBSCRIBED before me this , 201( . %?v Pub 42tary lic c F TARIAL SEAL TTA ROBINSON Notary TY.PHILADELPHIA COUNTY n Expires Mar 23, 2015 .. ig i k MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff /Z59-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4265 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 05/18/2011 to Defendant, PAUL C YESAVAGE , against whom judgment is to be entered after the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A copy of said Notice dated 05/18/2011, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE & NEEDLEMAN, P.C. BY: JOANN N DLEMAN, ESQ. Attorney for Plaintiff Date: June 1, 2011 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff (l1S) "/2Sy-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4265 CERTIFICATION OF ADDRESSES It is hereby certified that the parties have the following addresses: Plaintiff: FORD MOTOR CREDIT COMPANY P.O. Box 6058 MESA AZ 85216 Defendant: PAUL C YESAVAGE, 323 S. PITT ST, CARLISLE, PA 17013-3817 JOAN I- ey for Plaintiff MAURICE & NEEDLEMAN, P.C. BY: Date: June 1, 2011 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 1J) /69-/1-1)l FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-4265 AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA SS. I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, PAUL C YESAVAGE , is over 18 years of age; the occupation of Defendant is unknown and to the best of Plaintiffs knowledge, information and belief, Defendant is not in the military service of the United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. MAURICE & N C BY: SWORN TO AND SUBSCRIBED bef e me this y , 2011 Notary Public JOANN Attorney LEMAN, P.C. Plaintiff , ESQ. NOTARIAL SEAL RASHETTA ROBINSON Notary Public PHILADELPHIA CITY, PHILADELPHIA COUNTY MY Commission Expires Mar 23. 2015 a Attorneys at Law site 935, One Penn Center 517 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 tax 215.563.8970 www Milawpc.com Donald S. Maurice Member NJ Bar Board Certified Creditors' Rights Law rican Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Dominczyk Member NJ, NY & PA Bar Rachel Mann Member NY & NJ Bars New Jersey Office Aaunce & Needleman, P.C. Suite 2007 5 Waller E. Foran Blvd. Flemington, NJ 08822 tel. 908.237.4550 fax 908237.4551 May 18, 2011 PAUL C YESAVAGE 323 S. PITT ST CARLISLE, PA 17013-3817 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. PAUL C YESAVAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 104265 Dear Mr/Mrs/Ms YESAVAGE: Our File No. 11411 Enclosed please find a ten (10) day notice of default which is self- explanatory. This is being served upon you due to your failure to respond to Plaintiffs Complaint served upon you on April 19, 2011 . Unless an answer to Plaintiff s Complaint is filed with the Court within ten (10) days from the date of this notice, a default judgment may be entered against you. If you would like to discuss a resolution to this matter, please call our office at 908-237-4571 and ask for Kim Crosby. Thank you for your prompt attention to this matter. Very truly yours, MAURICE & NEEDLEMAN, P.C. Joann eedleman, Esq. JN/dIh Enc THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 Attorneys for Plaintiff 15) 789-7155 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. PAUL C YESAVAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 104265 IMPORTANT NOTICE TO: PAUL C YESAVAGE DATE: May 18, 2011 323 S. PITT ST CARLISLE, PA 17013-3817 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGEMENT MAY BE ENTERED AGAINST YOU 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: CUMBERLAND COUNTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 2 Liberty Avenue. Carlisle, PA 17013 (717)249-31,66 MAURIC EDLEMAN, P.C. 1 BY JOANN NE LEMAN, ESQUIRE Attorney for Plaintiff -0 cn K D Oc az- mmn m m =zz Dz0 ?nm M ?Z o M C) ;o M z C) w D D - w C = N inT m -?i m DAD mD 0m m _ ca w = OD - V = T -n -< O -4.0 C: 40 ?rn00 ?,ms> L6L£859000SZ90 I 4?1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy e„ Richard W Stewart Solicitor 1J ME OF THE S RWIP Ford Motor Credit Company vs. Case Number Paul C. Yesavage 2010-4265 SHERIFF'S RETURN OF SERVICE 04/1912011 03:45 PM Jody Smith, Chief Deputy, who being duly sworn according to law, states that on April 19, 2011 at 1545 hoursshe served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Paul C. Yesavage, by making known unto himself personally, at The Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $40.00 April 20, 2011 ?.. S .b CL JODY S. SMITH, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF (c) GOLMIStdte Sheriff, TveoW..t. In,. Request for Military Status Department of Defense Manpower Data Center 10 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 JUL-31-2009 05:16:46 •. Last Name First/Middle Begin Date Active Duty Status Service/Agency YESAVAGE PAUL Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. 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 Military. rte, a 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 Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further 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 current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: littp w,..N?x,,,.defenselink,.mil/faql"pis,;'PC09SLDR.htmI WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BWWPPAELNUW https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/31/2009