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HomeMy WebLinkAbout11-8857 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRO CREDIT SOLUTIONS Plaintiff, NO. 2011-8857 V. Brandon K. Gandy Amelia D. Gandy Defendant C a c - c -u n rn a- MC) w -? CO ;0 Type of Pleading PRAECIPE FOR DEFAULT JUDGEMENT Filed on behalf of: Pro Credit Solutions Plaintiffs Counsel of Record: THOMAS L. MAHER, ESQ. Pa I.D. #207970 PO Box 582 Greensburg, Pennsylvania 15601 (412) 583-3123 NOTICE THIS IS AN ATTEMPT BY A DEBT COLLECTOR TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRO CREDIT SOLUTIONS Plaintiff, V. : Brandon K. Gandy Amelia D. Gandy Defendant NO: 2011-8857 PRAECIPE FOR DEFAULT JUDGEMENT To the Prothonotary; Kindly enter Judgment against the Defendant, above named, and in favor of the Plaintiff, in the default of an Answer, in the amount of $13,602.93. Amount claimed in Complaint $13,410.93 Court Fees $ 92.00 Sheriff s Fees $ 100.00 Total $13,602.93 1(a. 5b PO ATr/ e-* 71 I7 P'' *93yy N04ke W.lw By: ?L, _ F -A _ Thomas L. Maher Esq ID # 270970 Attorney for Plaintiffs Pro Credit Solutions I hereby certify that an appropriate Notice of Default, as attached, has been mailed in accordance with PA R.C.P. 237.1 on the date indicated on the Notice. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pro Credit Solutions, Plaintiff, V. Brandon K. Gandy Amelia D. Gandy CASE NO.: 2011-8857 Defendant(s) 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), Brandon K. Gandy, above named, is over 21 years of age, is last known to reside at 5 Coral Drive 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: December 30, 2011c. Thomas L. Maher Esq ID # 270970 Attorney for Plaintiffs Pro Credit Solutions Request for Military Status Page 1 of 2 Department of Defense Manpower Data Center Dec-30-2011 06:58:33 41 Military Status Report Pursuant to the Service Members Civil Relief Act < Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Name BRANDON Based on the information you have furnished, the DMDC does not possess GANDY 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). 4t 00,4 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 1/30/2012 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Dec-30-2011 06:59:57 C Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency GANDY AMELIA 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). 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.ctmdc.osd.mil/appj/scra/popreport.do 1/30/2012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRO CREDIT SOLUTIONS Plaintiff, V. Brandon K. Gandy Amelia D. Gandy Defendant NO: 2011-8857 NOTICE OF JUDGMENT OR ORDER ( x ) Notice if hereby given that a DEFAULT JUDGMENT in the above captioned matter has been entered against you in the amount of $13,602.93, plus interest, on - , 21J0.n 3 '12012. ( ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. J4notary Ci By: If you have any questions regarding this Notice, please contact the filing party. Date: December 30, 2011 (This notice is given in accordance with Pa. R.C.P. 236.) NOTICE SENT TO: Brandon K. Gandy 5 Coral Drive Carlisle, PA 17013 ?? lam( Thomas L. Maher Esq ID #270970 Attorney for Plaintiffs Pro Credit Solutions 888-793-3238 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRO CREDIT SOLUTIONS Plaintiff, v. Brandon K. Gandy Amelia D. Gandy Defendant NO: 2011-8857 NOTICE OF JUDGMENT OR ORDER ( x ) Notice if hereby given that a DEFAULT JUDGMENT in the above captioned matter has been entered against you in the amount of $13,602.93, plus interest, on 201 l.? -?ax+ 3 , aura ( ) A copy of all documents filed with the Prothonotary in rt o e wi judgment is/are attached. Division By: If you have any questions regarding this Notice, please contact the filing party. Date: December 30, 2011 Thomas L. Maher Esq ID # 270970 Attorney for Plaintiffs Pro Credit Solutions 888-793-3238 (This notice is given in accordance with Pa. R.C.P. 236.) NOTICE SENT TO: Amelia D. Gandy 5 Coral Drive Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRO CREDIT SOLUTIONS, Plaintiff, VS. Brandon K. Gandy Ameila D. Gandy, Defendant(s), CASE NO.: 2011-8857 TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: Brandon K. Gandy IMPORTANT NOTICE PURSUANT TO PA.R.C.P. 237 1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN 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 JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HARING AND YOU MAY LOSE YOUR PROPRETY 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. Lawyer Referral Service Court Administrator 4t' Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Dated: December 19, 2011 cl/? NI Thomas Maher Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PRO CREDIT SOLUTIONS, ) Plaintiff, ) VS. ) CASE NO.: 2011-8857 Brandon K. Gandy ) Ameila D. Gandy, ) Defendant(s), ) TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: Amelia Gandy IMPORTANT NOTICE PURSUANT TO PA.R.C.P. 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN 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 JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HARING AND YOU MAY LOSE YOUR PROPRETY 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. Lawyer Referral Service Court Administrator 4'h Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Dated: December 19, 2011 Thomas Maher Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEEVSI,VI?aA zm ;V m cav rnF CIVIL DIVISION X es C:) Pro Credit Solutions ) A ° c') Vic: ?? Plaintiff, ) _ ?{ V. Brandon K.Gandy, Amelia Gandy, Defendant, Docket No. 2011-8857 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: February 13, 2012 i 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. Brandon K. Gandy, Amelia D. Gandy Defendant (s), Docket No. 2011-8857 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: January 23, 2012 Thomas L. Maher, Esq. Attorney for Plaintiff PA I.D. 207970 Pro Credit Solutions COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND T" Siatf7oN(; : Plaintiff File No. vs. ?? q a K CbAN3D n%L' A b fendant SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: L12 !.?/ `/ M4(-0eNR31-- t (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 or things: nn VAN l J9 W P OBI.- R- j C- O L?) Itf -?, ?)r-- r-F PO -NTs A-; 715? AN3,r 5 at 1?-lj? D Pk €5S (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: NAME: U- I.YJ PAA 5 Z-- . ?AANC-- j 66 "l ADDRESS: 01 TELEPHONE: . ' -- -? SUPREME COURT ID # ATTORNEY FOR: BY THE Prothonotary, Civil Date:_ "7 ) ) p i ?! i 11 Sell of th Court WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-8857 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due PRO CREDIT SOLUTIONS Plaintiff (s) From BRANDON K. GANDY AND AMELIA D. GANDY, 5 CORAL DRIVE, 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 levied upon in the possession of GARNISHEE(S) as follows: BLUE CHIP FEDERAL CREDIT UNION 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$13,602.93 L.L.$.50 Interest FROM 1/3/2012 TO 2/24/2012 - $118.51 Atty's Comm % Due Prothy $2.25 Arty Paid $190.44 Other Costs Plaintiff Paid Date: 2/27,112 • / David D. Buell, Prothonot (Seal) Deputy REQUESTING PARTY: Name THOMAS L. MAHER, ESQUIRE Address: F.O. BOX 582 GREENSBURG, PA 15601 Attorney f6r: PLINTIFF Telephone: 1-888-793-3238 Supreme Court ID No. 207970 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Pro Credit Solutions, Plaintiff, ) V. ) Brandon K. Gandy ) r Amelia D. Gandy, xs Defendant(s), ) NO. 2011-8857 r - v PRAECIPE FOR WRIT OF EXECUTION n ''j '. --r C n TO THE PROTHONOTARY: "' Issue writ of execution in the above matter, directed to the Sheriff of Dauphin County: (1) against Brandon K. Gandy as defendant(s). (2) against Blue Chip Federal Credit Union as garnishee(s). (3) and index this writ (a) against Brandon K. Gandy, defendant(s) AMOUNT DUE $13,602.93 INTEREST From 1/3/2012 TO 2/240/2012 $ 118.51 ---------------- SUBTOTAL: $13,721.44 ADD INTEREST FROM 2/24/2012 ADD COSTS TOTAL 0) Thomas L. Maher, Esq. ate} c , p? a t?l Attorney for Plaintiff So q CC?F PA I.D. 207970 q a do Pro Credit Solutions C/y ally a-71s?? I ?1?? dr e?x ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pro Credit Solutions v. Brandon K. Gandy, Plaintiff, Defendant, CIVIL DIVISION G .; -1 :ti= r-- t cp , (....nr-- ...s, 4 . r C7 -'0 11- 8857 0 , docket No. 2011 99999 , 7'1"7:: ..,..- --t ''ci,'1 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: July 29, 2014 Jason . DiNardo Pro Credit Solutions IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Pro Credit Solutions, v. Brandon K. Gandy, Plaintiff, Defendant, CIVIL DIVISION Docket No. 2014-99999 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: July 8, 2014 Jason . DiNardo Pro Credit Solutions COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ii2r0 C 1't 4 5 LJ -t, -b 1n4` VS. 6{6a4.o,r. K 6co„ Plaintiff Defendant FileNop9O/U— Crq9q9 SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: C ks rI 612(-\ 0/6.01.i 4- 66\.1 o (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 or things: 411 f -.v, -6k a- \ -c,na-V‘l..tcs-( 40C-0-W..a'4S o oGi ai 2�( at PO IGO 0� ff 2.v�S�W.-se)...1 (o O ) (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 ISSUEDr AT THE REQUEST OF THE FOLLOWING PERSON: NAME: Aso 6. A A. bi J rcL ADDRESS: C9.8,stc 5g TELEPHONE: (— 793 — gR 3r SUPREME COURT ID # ATTORNEY FOR: Date: Seal o' the Court Deputy