HomeMy WebLinkAbout11-1690
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Pro Credit Solutions,
Plaintiff,
V.
Jerry Manley
Defendant(s)
CASE NO.: )/- 100 m'l l
PRAECIPE FOR ENTRY OF JUDGMENT AND CERTIFICATION OF ADDRESS
1. Enter judgment on the attached certified copy of Judgment from a District Judge.
a. Date of Judgment: 12/28/2010
b. Certified Judgment Total: $ 4,439.47, plus interest & court costs.
2. Enter the judgment in favor of Plaintiff, Pro Credit Solutions, as named on the
accompanying transcript, and against Defendant(s), Jerry Manley.
3. I hereby certify that the precise address of the judgment creditor, Pro Credit Solutions, is
as set forth in the cover page.
4. I hereby certify that the last known address of the defendant(s) is:
Jerry Manley
321 Cornman Road
Carlisle, PA 17013
Dated: February 9, 2011
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Jason DiNardo -:i
Pro Credit Solutions _
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Mag. Dist. No: MDJ-09-2-01
MDJ Name: Honorable Paula P. Correal
Address: 2260 Spring Road, Suite 3
Carlisle, PA 17013
Telephone: 717-218-5250
Pro Credit Solutions
P.O. Box 582
Greensburg, PA 15601
Disposition Summary
Docket No Plaintiff
MJ-09201-CV-0000184-2010 Pro Credit Solutions
Defendant
Jerry Manley
Notice of Judgment/Transcript Civil
Case
Pro Credit Solutions
V.
Jerry Manley
-11 04'yalr e vl Pei,
(161 Vji S I , i?A 17e i3
Docket No:
Case Filed:
MJ-09201-q,
Y-000g184C-2010
11/24/201 Or-
a -? n
Disposition Disposition Date
Default Judgment for Plaintiff 12/28/2010
Judgment Summary Joint/Several Liability Individual Liability Amount
Participant
Jerry Manley $0.00 $4,439.47 $4,439.47
Judgment Detail (*PostJudgment)
In the matter of Pro Credit Solutions vs. Jerry Manley on 12/28/2010 the disposition is Default Judgment for Plaintiff and judgment was
awarded as follows:
Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $4,291.47 $4,291.47
Filing Fees $0.00 $148.00 $148.00
Grand Total: $4,439.47
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 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 JUDGMENT
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.
1a a8 1a
Date
gisterial District Judge Paula P. Correal
Ma
I certify that this is a true and correct copy of the record of th proceed in ontaini a judg ent.
411 71/ '41,
Date Magisterial District Judge Paula P. Corre I
MDJS 315 Page 1 of 1 Printed: 02/01/2011 12:36:27PM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Pro Credit Solutions,
Plaintiff,
V.
Jerry Manley
Defendant(s)
CASE NO.:
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
The undersigned, being duly sworn according to law, depose and say that I am the
Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and
belief Defendant(s), Jerry Manley, above named, is over 21 years of age, is last known to reside
at 321 Cornman Road Carlisle, PA 17013; is not in the military service of the United States or its
Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of
Congress of 1940 and its Amendments.
Date: February 9, 2011 s. """
Jason DiNardo
Pro Credit Solutions
jxequest for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Feb-09-2011 07:56:46
<. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
MANLEY JERRY L Based on the information you have furnished, the DMDC does not 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).
14. vfO414, -
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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
"defense] ink.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 2/9/2011
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
cnf'
In the Matter of: r-? N
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PRO CREDIT SOLUTIONS
v -'
Jerry Manley
NO: 2011-1690
PRAECIPE FOR APPEARANCE
Please enter my appearance in the above-designated matter on behalf of PRO CREDIT
SOLUTIONS
I am authorized to accept service on behalf of said participant in this matter.
On the basis of this notice, I request a copy of each document hereafter issued by the
COUNTY OF Cumberland in this matter.
cla, ftt,
Thomas L Maher, Esquire
Atty. I.D. 207970
Attorney for Plaintiff
P.O. Box 582
Greensburg, PA 15601
1;888)-793-3238
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions
Plaintiff,
v.
Jerry Manley,
Defendant,
Docket No. 2011-1690
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777
CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE
4009.22
Pro Credit Solutions certifies that:
(1) A notice of intent to serve the subpoena with a copy of the subpoena attached thereto was mailed or
delivered to each party at least twenty days prior to the date on which the subpoena is sought to be
served,
(2) A copy of the notice of intent, including the proposed subpoena, is attached to this certificate,
(3) No objection to the subpoena has been received, and
(4) The subpoena which will be served is identical to the subpoena which is attached to the notice of
intent to serve the subpoena.
DATE: March 17, 2011
Thomas L. Maher, Esq.
Attorney for Plaintiff
PA I.D. 207970
Pro Credit Solutions
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions,
Plaintiff,
V.
Jerry Manley,
Defendant,
Docket No. 2011-1690
NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.21
Pro Credit Solutions intends to serve a subpoena identical to the one that is attached to this notice. You
have twenty (20) days from the date listed below in which to file of record and serve upon the
undersigned an objection to the subpoena. If no objection is made, the subpoena may be served.
DATE: February 25, 2011
- ??X' ?? L-
Thomas L. Maher, Esq.
Attorney for Plaintiff
PA I.D. 207970
Pro Credit Solutions
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Pro Credit Solutions 2011-1690
Plaintiff File NO.
VS.
Jerry Manley
Defendant
SUBPOENA TO PRODUCE DOCUMENTS OR THINGS
FOR DISCOVERY PURSUANT TO RULE 4009.22
t r,a(iC1AJ
TO: if tf l'
(Name of Person or Entity)
Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the
following documents y or things: RN I N? ` ?A`
+?t- XbOYe OVw (?Otat-. t?l
at?ti) C( t? SoliilIAUAy 5$3 I
(Address)
You may deliver or mail legible copies of the documents or produce things requested by this
subpoena, together with the certificate of compliance, to the party making this request at the address listed
above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the
things sought.
If you fail to produce the documents or things required by this subpoena within twenty (20) days
after its service, the party serving this subpoena may seek a court order compelling you to comply with it.
THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOWING PERSON:
N.1>u1F: :1`.`9h1r?? :., NLfaieeEc? S_.5
ADDRESS: f.0 gon E R-a
&rP-tn10LAfa 26-4160i
TELEPHONE: I -It 8 -14 3 - 3A 3 8
SUPREME COURT ID # d C 19 1
ATTORNEY FOR: P i kia+-? -
Y THE COU
Prothonotary, Civil Division
Date: a? - I i
Seal of the Cou-t Deputy
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-1690 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PRO CREDIT SOLUTIONS Plaintiff (s)
From JERRY LEE MANLEY, 321 Corman Road, Carlisle, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell ANY AND ALL
PROPERTY BELONGING TO THE DEFENDANT AT 321 CORMAN ROAD, CARLISLE,
PA 17013.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
SOVEREIGN BANK, 99 OLD YORK ROAD, NEW CUMBERLAND, PA 17070
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;
(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 $4,439.47
L.L.$.50
Interest $72.25
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 4/8/11
(Seal)
REQUESTING PARTY:
Name THOMAS L. MAHER, ESQURE
Address: P.O. BOX 582
GREENSBURG, PA 15601
Attorney for: PLAINTIFF
Telephone: 888-793-3238
Supreme Court ID No. 207970
David D. Buell, Prothonotary
By: _ , - a? 2 ?-' Depu
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IN THE COURT OF C OMMON PLEAS OF CUMBERLAND COUNTY, PENNS VLV C1Ii
CIVIL DIVISION ?
ca-r;
PRAECIPE FOR WRIT OF EXECUTION ?p q
Pro Credit SOIUtIOnS ? Confessed Judgment CA
)
Plaintiff ? Other -4 I
vs. Fite No. 2011-1690
Jerry Lee Manley Amount Due $4,439.47
Defendant Interest $ 72.25
Address: Atty's Comm
321 Corman Road Costs
Carlisle, PA 17013
TO THE PROTHONOTARY OF THE SAID COURT:
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 pursuant to Act 6 of 1974 as
amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs, upon the following described property of the defendant (s)
Any and all property belonging to the Defendant, including three attached vehicles at:
321 Corman Road
Carlisle, PA 17013
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland 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 list)
Sovereign Bank, 99 Old York Road, New Cumberland, PA 17070
and all other property of the defendant(s) in the possession, custody or control of 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.
O Date 4/6/2011 Signature: -
S
O0 ?. ? ,? a Print Name: Thomas L. Maher, Esq.
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Address: P.O. Box 582
Attorney for:
Telephone:
Greensburg, PA 15601
Pro Credit Solutions
1-888-793-3238
Supreme Court ID No: 207970
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COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
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In the Matter of.
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PRO CREDIT SOLUTIONS =c rj'
v
Jerry Manley
NO: 2011-1690
PRAECIPE FOR APPEARANCE
Please enter my appearance in the above-designated matter on behalf of PRO CREDIT
SOLUTIONS
I am authorized to accept service on behalf of said participant in this matter.
On the basis of this notice, I request a copy of each document hereafter issued by the
COUNTY OF Cumberland in this matter.
rtA-
Thomas L Maher, Esquire
Atty. I.D. 207970
Attorney for Plaintiff
P.O. BOX 582
Greensburg, PA 15601
(888)-793-3238
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
Sheriff (j' THE PROTHONOTARY
Jody S Smith 2011 APR 18 PM 1: 22
Chief Deputy
Richard W Stewar? CUMBERLAND COUNTY
Solicitor OFF C ? - PENNSYLVANIA
Pro Credit Solutions
vs. Case Number
Jerry L. Manley 2011-1690
SHERIFF'S RETURN OF SERVICE
04/15/2011 09:0 AM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April
15, 011 at 0906 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
mon es of the within named defendant, to wit: Jerry L. Manley, in the hands, possession, or control of the
within named garnishee, Sovereign Bank at 17 W High Street, Carlisle, Cumberland County, Pennsylvania
170 3, by handing to Julie Myers, Branch Operations Manager, personally three copies of interrogatories
toge her with three true and attested copies of the writ of execution and made the contents there of known
to h r.
April 18, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
Michelle Gutshall, Deputy
dpi Gbun'ySIAE, Shenft, Ie!eosott, It c.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Pro Credit Solutions,
V.
Jerry Manley,
and,
Sovereign Bank,
Plaintiff,
Defendant,
Garnishee,
Docket No. 2011-1690
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CID
PRAECIPE TO DISCONTINUE AGAINST GARNISHEE(S) ONLY
TO THE PROTHONOTARY:
Please discontinue this action against the above garnishee(s), Sovereign Bank and mark the
docket accordingly.
?r,? (r(r3o
,?Cf6 ?5s&s?
Thomas L. Maher, Esq
Attorney for Plaintiff
PA I.D. 207970
Pro Credit Solutions
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Pro Credit Solutions,
v.
Jerry Manley
Plaintiff,
Defendant,
Docket No. 2011-1690
-0
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-5 f.
CD t
•
PRAECIPE TO SATISFY
TO THE PROTHONOTARY:
Please mark the above -captioned Judgment as paid and satisfied in full releasing the
defendant and the garnishee from all matters regarding this case.
Jason .D iNardo
Pro Credit Solutions
Dated: August 6, 2014
44.