HomeMy WebLinkAbout11-9131SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ari ?:ianG? I
Ca :L
THE PROT'HONOTAR? "
Jody S Smith
Chief Deputy 201 1 DEC 22 PH 2.33
Richard W Stewart
Solicitor CUMBERLAND COUNTY
PENNSYLVANIA
Capital One Bank Case Number
vs. 2011-9131
Thomas P. Lacey
SHERIFF'S RETURN OF SERVICE
12/13/2011 08:03 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on
December 13, 2011 at 2003 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Thomas P. Lacey, by making known unto Jackie Lacy, Wife of Defendant
at 6252 Billingsgate Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at
the same time handing to her personally the said true and correct copy of the same.
RONALD HOOVER, DEPU
SHERIFF COST: $38.00
December 16, 2011
SO ANSWEERSSf?,,
RON R ANDERSON, SHERIFF
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
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CAPITAL ONE BANK (USA), N.A. XM rn rn--
NUMBER: 11-9131-C;kg N -U'M
VS. rz --io
THOMAS P LACEY
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PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGE ° ?.7
TO THE PROTHONOTARY:
Kindly enter judgment in favor of Plaintiff and against the
Defendant(s) THOMAS P LACEY for failure to answer
Plaintiff's Complaint, endorsed with twenty (20) day notice to plead,
served upon Defendant(s) on DECEMBER 13, 2011 and assess damages as
follows:
Unpaid Balance: $18,044.80
Plus Interest: $1,814.76
Additional Charges: $.00
Plus Attorney's Fees: $.00
Less Credits, if any: $.00
TOTAL DUE: $19,859.56
Pursuant to PaR.C.P.237.1, I hereby certify that notice to fil his
Praecipe was mailed to the above named Defendant(s) and the A rney
of Record (if applicable) on JANUARY 18, 2012 and copy/copie
of the same is/are attached hereto.
By:
ARTHUR LASHIN, ESQUIRE
Attorney for the Plaintiff
LAW OFFICES OF
HAYT, HAYT & LANDAU, LLC
123 S. Broad Street
Suite 1660
Philadelphia, Pennsylvania 19109-1003
(215) 928-1400
+11.50 PO Ate`{
et Ito 4501
No-hbe ? ?
COURT OF COMMON PLEAS
VERIFICATION OF NON-MILITARY SERVICE
CAPITAL ONE BANK (USA), N.A.
COMMONWEALTH OF PENNSYLVANIA
- VS -
THOMAS P LACEY
COUNTY OF PHILADELPHIA
I represent the Plaintiff in the above entitled case and am
authorized to make this verification. I make this verification on
behalf of the Plaintiff upon information and belief: the above named
Defendant(s) is/are 18+ years of age; the address of the Defendant(s)
is/are
THOMAS P LACEY
6252 BILLINGSGATE
MECHANICSBURG, PA 17050
the occupation of Defendant(s) is unknown; and the Defendant(s) is/are
not in the Military Service of the United States, nor any State of
Territory thereof and its Allies as defined by the Servicemembers
Civil Relief Act, 50 U.S.C. section 521. /J
By:
ARTHUR LASHIN, Esquire,
Attorney for Plaintiff
I verify that the statements made in this verification are true
correct upon information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa.?
section 4904 relating to unsworn falsification to authorities
By:
ARTHUR LASHiN, h;squlre,
Attorney for Plaintiff
LAW OFFICES OF
HAYT, HAYT & LANDAU, LLC
By: Arthur Lashin, Esquire
Identification No. 23425
123 S. Broad Street
Suite 1660
Philadelphia, PA 19109-1003
(215) 928-1400
/ITTn =T= ATn.
Attorney for Plaintiff
DATE: JANUARY 18, 2012
CAPITAL ONE BANK (USA), N.A.
4851 COX ROAD
GLEN ALLEN, VA 23060
VS.
THOMAS P LACEY
6252 BILLINGSGATE
MECHANICSBURG PA 17050
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM.
No. 11-9131-CIVIL
NOTICE OF INTENTION TO TAKE DEFAULT
PURSUANT TO PA.R.C.P 237.1
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 judgment 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
32 S BEDFORD STREET
CARLISLE PA, 17013
800-990-9108
By:
ARTHUR LASHIN