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HomeMy WebLinkAbout12-0263IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 Date: Defendant No. 12-263 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT r . c-, _ c: .. ? , { Filed on ehalf of Plaintiff Coun-Al o record for this Part Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff i t . sopd a Spa ),3 d> ?ULl SaS : ?I1ect ??1 i 4Q-7gS7b is alp attempt to ,?<_ c ?t. I?"11i communication is # c??l a debt collector' A 4-, t bt, -1 '111, >A C- I , I, t 111 All -iATM 1411 (.) ,UA1 t. kyl t-, ul?L tYA A't. j'jL4gyV. _. Nofi? 1 y?? d IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff No. 12-263 CIVIL TERM V. MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 Defendant PRAECIPE FOR DEFAULT JUDGMENT Please enter Judgment in Favor of Plaintiff and against Defendant, MICHELLE L FIFE , for failure to answer the Complaint. (X) Amount Due $1,598.91 Less Credits $.00 TOTAL $1,598.91 (X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to PA.R.C.P.237 (Notice for Final Judgment or Decree), I certify that a copy of this praecipe has been mailed to each other party who appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P.23 1. 1, I certify that a written notice of intention to file this praecipe was mailed or delivered to the party against whom judgme is to be entered and Ainr?is/her Attorney of record, if any, after the default occurred and at least n ays prior to the d, 4e o the filing of this praecipe and a copy of the notice is attached. ® k a„\ Date: _ Robert N. Polas, Jr., Esquire # 20125 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff "hip coinimmication is from a debt collector is an atte apt to collet Ally information obtained will be used I'Or that t)LJ1j)0SC, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140 Corporate Boulevard Norfolk, VA 23502 Plaintiff V. MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 Defendant No. 12-263 CIVIL TERM NOTICE OF JUDGMENT (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $1,598.91, plus interest, on. (X) A copy of all documents filed with the Prothonotary in support of By: If you have any questions regarding this Notice, please Date: Robert N. Polas, Jr., Esquire # 201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0806 Attorneys for Plaintiff l`his communication is fi•orn a debt collector;'-, all ;ate ELI 1't to collec An 'nfotrntation obta'ned will N i ' r t°?, -Irpos . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY 140 Corporate Blvd. Norfolk, VA 23502 V. MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 TO: MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 ASSOCIATES, LLC Plaintiff Defendant DATE OF NOTICE: February 27, 2012 No. 12-263 CIVIL TERM IMPORTANT NOTICE 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. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 Pennsylvania Lawyer Referral Service (800) 692-7375 Robert N. Polas, Jr., Esquire Carrie A. Brown, Esquire Attorney ID # 201259/94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, Va 23502 Attorneys for Plaintiff This communication is from a debt collector is an attempt to collect a debt. Any information obtained will be used for that purpose. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATE, LLC 140 Corporate Blvd. Norfolk, VA 23502 Plaintiff V. MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 Defendant No. 12-263 CIVIL TERM AFFIRMATION OF NON-MILITARY SERVICE The undersigned counsel, as attorney for plaintiff, herein affirms under the penalties of perjury that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief, the above named Defendant, is over 21 years of age; is last known to reside at 150 TORY CIR ENOLA PA 17025 and is not in the military service of the United States or its Allies, or otherwise within the provisions of the Service Members Civil Relief Act and its Amendments. Date: 11-12145 t ? j b? Robert N. Polas, Jr., Esquire, #201259 Carrie A. Brown, Esquire, #94055 Portfolio Recovery Associates, LLC 140 Corporate Blvd. Norfolk, VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attorneys for Plaintiff ?_'01111'i11111ication 1s a debt collector and N an atlelnpt to Collect a debt, i :Iorni ition obtained will be tised for that purpose. Department of Defense Manpower Data Center Mar-16-2012 15:58:22 Aooftb% Military Status Report 11-12145 Pursuant to the Service Members Civil Relief Act Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Name Agency FIFE MICHELLE 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). 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/PCOgSLDR.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. 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:SL1 KOPPGM5 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-263 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff (s) From MICHELLE L. FIFE, 150 TORY CIRCLE, ENOLA, PA 17025 (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: AMERICHOICE FCU, 2175 BUMBLE BEE HOLLOW ROAD, MECHANICSBURG, PA 17055 - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. 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$1,598.91 L.L. S.50 Interest FROM APRIL 10, 2012 (AT AN INTEREST RATE OF 6% PER YEAR) Atty's Comm % Due Prothy $2.25 Atty Paid $194.75 Other Costs Plaintiff Paid Date: JUNE 18, 2012 David D .-Buell, Prothonot (Seal) By: Deputy REQUESTING PARTY: Name : ROBERT N. POLAS, JR, ESQUIRE Address: 140 CORPORATE BLVD. NORFOLK, VA 23502 Attorney for: PLAINTIFF Telephone: 866-428-8102 Supreme Court ID No. 201259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES, LLC 140 CORPORATE BLVD. NORFOLK, VA 23502 PLAINTIFF vs. MICHELLE L FIFE NO. 12-263 CIVIL TERM 150 TORY CIR ENOLA PA 17025 == DEFENDANT(S) PRAECIPE FOR WRIT OF EXECUTION - MONEY JUDGMENTS TO THE PROTHONOTARY: -c a - - ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. :?S a: (1) Direct to the Sheriff of CUMBERLAND County, PA; (2) against MICHELLE L FIFE, Defendant(s); V, c? (3) and against AMERICHOICE FCU, Garnishee(s); (4) And index this writ (A) against MICHELLE L FIFE, Defendant(s) (B) and against AMERICHOICE FCU, Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of the garnishee(s). Specifically describe the property per attached property description. All accounts including but not limited to all savings, checking and er accounts, cert i tes of deposit, notes receivables, collateral, pledges, documents of title, securities, cou o and safe deppts t oxes. (5) Amount Due: $1,598.91 Signature/lD Number Interest From April 10, 2012: (At an interest rate of 6% per year) Total: (Total includes post judgment credits) c ?. y3. c>o 6F )a3??,?ttM it?.5o t??t Ila a. a-Vol 11-12145 as wed S • sv ???} ? 8 t S 38 ?SSv-? a?u Mks A ? This comma 1*ikp } g ?> >"RWSW11ect a debt. Robert N. Polas, Jr., Esq. #201259 Print Name Plus costs & interest Carrie A. Brown, Esq. #94055 Address 140 Corporate Boulevard Norfok VA 23502 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy F It 4 C** OF TFi? ??THONDTARY 2012 JUN 27 AM 8: 42 Richard W Stewart Solicitor CN PYLVRN?TY Portfolio Recovery Associates, LLC vs. Michelle L. Fife SHERIFF'S RETURN OF SERVICE Case Number 2012-263 06/22/2012 11:36 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2012 at 1136 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michelle L. Fife, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union, 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Don Gray, Senior Loan Officer, 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 him. The writ of execution and notice to defendant was mailed on June 25, 2012 to Michelle L. Fife, 150 Tory Circle, Enola, PA 17025. SO ANSWERS, June 25, 2012 RON R ANDERSON, SHERIFF Noah Cline, eputy c oumySuite Sheriff t.le sott. In": IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY; PA CIVIL AC77ON - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 140-Corporate Boulevard Norfolk, VA 23502 V. Plaintiff`' No. 12-263 CIVIL TERM ? MICHELLE L FIFE 150 TORY CIR ENOLA PA 17025 Defendant. rz PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE JUDGMENT IN THE ABOVE-CAP77ONED ACTION AS S877LED SATISFIED. Submitted, Carrie A. Brown, Esquire, #940- Robert N. Polas, Jr., Esquire 4`2011259 Portfolio Recovery Associates, LbC 140 Corporate Blvd. NorfW VA 23502 (T) 1-866-428-8102 (F) 757-518-0860 Attomey far Plainfiff 11-12145 am C= N N oh err Q R'n = ..r This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. SHERIFF'S OFFICE OF CUMBERLAND COUNTY .onnyRAnderson FILED:_001CL Sheriff at+ iitr�b '_F THF .PR0TH0!` 0DtR`t' yip 1, �. Jody S Smith j Chief Deputy 2013 MAR 15 AM 9: 54 Richard W Stewart CUMRLAN3i1bTY Solicitor OFFICE OF THE SNERIFF P1=NNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Michelle L. Fife 2012-263 SHERIFF'S RETURN OF SERVICE 06/22/2012 11:36 AM- Noah Cline, Deputy Sheriff,who being duly sworn according to law, states that on June 22, 2012 at 1136 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant,to wit: Michelle L. Fife, in the hands, possession,or control of the within named garnishee, AmeriChoice Federal Credit Union, 2j0 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055, by handing to Do*ray, Senior Loan Officer, 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 him. The writ of execution and notice to defendant was mailed on June 25, 201k1to Michelle L. Fife, 150 Tory Circle, Enola, PA 17025. 03/14/2013 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: $92.48 SO ANSWERS, March 14, 2013 RONIV R ANDERSON, SHERIFF ire. 9eSk 7 ," �S- 76- 7 (c)CountySuite Sheriff,Tel=_osoR..Inc.