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HomeMy WebLinkAbout12-2632Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Morris Scott Attorney I.D. #83587 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. SPENSER D LEADER 117 KIM ACRES DR MECHANICSBURG PA 17055 Defendant(s). PRAECIPE TO ENTER APPEARANCE AND ENTER JUDGMENT AND CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: Kindly ENTER my APPEARANCE on behalf of and ENTER JUDGMENT in favor of the PLAINTIFF PORTFOLIO RECOVERY ASSOCIATES LLC in this matter and against the DEFENDANT SPENSER D LEADER in the amount of $1,002.42 plus court costs in accordance with the judgment entered in the attached certified Notice of Judgment/Transcript. The amount herein may be lower than the judgment amount to reflect payments already made by the defendant. I, DANIEL SANTUCCI, hereby CERTIFY that the names and addresses of the plaintiff and Attorney for Plaintiff, PORTFOLIO RECOVERY ASSOCIATES 9'7 n r•j n 2: CT Z- L r c NJVFWNIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION /y ?a Ciuc I No. ? a - 2-C? defendant(s) are true and correct as designated in the above caption of this Dated: April 19, 2012 By: BLATT, HASE LE EIBSKER & MOORE, L C Daniel S Morris S 2674579 PPTXDJJI 1111111111111 III IINII IIIII IIIII IIIII IIIII 11111 IIIII 1111111 II IN ?? X31. ash a. ??soa ???, ao ul nab I-ecl PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff, vs. SPENSER D LEADER Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. TO: SPENSER D LEADER NOTICE PURSUANT TO Pa.R.C.P. 236 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. Dated:. q L?1( a PROTHONO RY By. w IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Morris Scott Attorney I.D. #83587 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2674579 PPTNDJJI 1111111111111 I I 1111111111111111111111111111111111111 I I I N I I I I IN ? Y COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ-09-3-05 MDJ Name: Honorable Mark Martin Address: 507 North York Street Mechanicsburg, PA 17055 Telephone: 717-766-4575 Portfolio Recovery Associates 120 Corporate Blvd Norfolk, PA 23502 Disposition Summary Docket No MJ-09305-CV-0000005-2012 Judgment Summary Participant Portfolio Recovery Associates SpenserD Leader Plaintiff Defendant Portfolio Recovery Associates Spenser D Leader Joint/Several Liability $0.00 $0.00 Individual Liability $0.00 $1,101.92 Amount $0.00 $1,101.92 Judgment Detail (`Post Judgment) In the matter of Portfolio Recovery Associates vs. Spenser D Leader on 3/09/2012 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Costs $0.00 $99.50 $99.50 Civil Judgment $0.00 $1,002.42 $1,002.42 Grand Total: $1,101.92 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 JUDGMENTITRANSCRIPT 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 REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 3 4 Date Magisterial District Judge Mark Martin certify that this is a true an correct copy o the recor o t e proceedings containing lu gmetnt. Date Magisterial istrict Judge Portfolio Recovery Associates V. Spenser D Leader Docket No: MJ-09305-CV-0000005-2012 Case Filed: 1/18/2012 Disposition Disposition Date Default Judgment for Plaintiff 03/09/2012 MDJS 315 Page 1 of 2 Printed: 03/09/2012 12:29:37PM P, Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, VS. CUMBERLAND COUNTY, PA SPENSER D LEADER CIVIL ACTION 221 N 2ND ST c') P-0 -"I LEMOYNE PA 17043-11022 zzi Defendant(s). No. 12-2632 CIVIL ::: e~� AND SOVEREIGN BANK tJ3r 1300 Camp Hill Byp � - Camp Hill, PA 17011 i C) Garnishee ' ' PRAECIPE FOR WRIT OF EXECUTION N _._ TO THE PROTHONOTARY: Kindly ISSUE a WRIT OF EXECUTION in the above matter, directed to the Sheriff of Cumberland County: (1) directed to the sheriff of Cumberland County; (2) against SPENSER D LEADER defendant[s]; and (3) against SOVEREIGN BANK garnishee[s]; (4) and enter this writ in the judgment index (a) against SPENSER D LEADER Defendant (5) Amount due $ Oc 1530° -�C = ` �71 Interest from $ 04-30-12 Costs to be added $ Morris Scott#83587 aOA} �0 1 ( Syretta Martin#309370 ,F Attorney for Plaintiff eo a�oL� 2674579 PPTGPWEI I� r o� 6S Kd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-2632 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES LLC C/O BLATT,HASENMILLER,LEIBSKER&MOORE,LLC Plaintiff(s) From SPENCER D. LEADER,221 N 2ND STREET,LEMOYNE,PA 17043 (1) You are directed to levy upon the property of the defendant(s)and to sell 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, 1300 CAMP HILL BYP,CAMP HILL,PA 17011 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, (2) 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$471.63 Plaintiff Paid$ Interest FROM 4/30/12-$7.06 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: 5/22/13 luuC( ,�.0 David D.Buell,Prothonotary t w: a Deputy REQUESTING PARTY: Name : MORRIS SCOTT,ESQUIRE Address: BLATT,HASENMILLER,LEIBSKER& MOORE,LLC 1835 MARKET STREET,SUITE 501 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-1567 Supreme Court ID No. 83587 Blatt, Hasenmiller, Leibsker& Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC IN THE COURT OF COMMON PLEAS c/o Blatt, Hasenmiller, Leibsker& Moore, LLC CUMBERLAND COUNTY, PA Plaintiff, CIVIL ACTION Vs. No. 12-2632 CIVIL SPENSER D LEADER T 221 N 2ND ST LEMOYNE PA 17043-1102 mco <_ Fr"f Defendant(s). <- r-r! CD Y r SOVEREIGN BANK 1300 Camp Hill Byp �CD _ ; Camp Hill,PA 17011 CD ry { Garnishee ' Interrogatories to Garnishee To SOVEREIGN BANK, Garnishee: You are required to file Answers to the following Interrogatories within 20 days after service upon you. Failure to do so may result in judgment against you. 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any? NO 2. At the time you were served or any subsequent time thereafter, was there in your possession, custody, control or in joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? YES-SEE ATTACH 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendants) or in which the defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had any interest? NO 2674579 PPTGBKCI 5. At any time before or after you were served did the defendant(s)transfer or deliver any property to you or to any person or place pursuant to your direction or consent and if so what was the consideration therefore? NO 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? NO 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or Federal law? If so, identify each account and state the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. NO 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant(s) have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S Sec.8123? If so, identify each account. NO 9. How much is the value of any property in your possession belonging to the defendant(s)? SEE ATTACH 10. In the space below,the plaintiff may set forth additional appropriate interrogatories. N/A Morris Scott, Attorney No. 83587 Syretta Martin, Attorney No. 309370 f . ) Verification I,DEBBIE LEWIS the undersigned representative of SOVEREIGN BANK, hereby verify that the answer to interrogatories are true and correct to the best of my knowledge, information, and belief based upon information I have. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to authorities. ANSWERS TO INTERROGATORIES Account # 1051152186 Balance: $63.25 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $0.00 Account Holder: SPENSER D LEADER 221 N 2ND ST LEMOYNE, PA 17043-1102 VERIFICATION I, Debbie Lewis, C.O.P. Process Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. vereign Bank By: Debbie Lewis C.O.P. Process Specialist THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PORTFOLIO RECOVERY ASSOCS., LLC VS. SPENSER D LEADER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Morris Scott, Esquire Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Service by certified mail addressed as follows: SPENSER D LEADER 221 N 2ND ST LEMOYNE, PA 17043-1102 1 Debbie Lewis C.O.P. Process Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 June 10, 2013 9.sc Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Morris Scott Attorney I.D. #83587 PORTFOLIO RECOVERY ASSOCIATES LLC Syretta Martin Attorney I.D. #309370 1835 Market Street, Suite 501 Philadelphia, PA 19103 215-564-1567 PORTFOLIO RECOVERY ASSOCIATES LLC c/o Blatt, Hasenmiller, Leibsker& Moore, LLC IN THE COURT OF COMMON PLEAS Plaintiff, VS. CUMBERLAND COUNTY, PA -,, SPENSER D LEADER r -; 221 N 2ND ST CIVIL ACTION — -� LEMOYNE PA 17043-1102 -nCO t— M:=- Defendant(s). No. 12-2632 CIVIL C= -K AND D SOVEREIGN BANK cam-- . 1300 Camp Hill Byp o rep r t Camp Hill, PA 17011 3-- Garnishee Z j PRAECIPE TO DISSOLVE ATTACHMENT To the Prothonotary: Kindly mark the Writ of Execution against SOVEREIGN BANK as,DISSOLVED, and the attachment as DISSOLVED. Respectfully submitted, Morris Scott Syretta Martin 2674579 1� aR p1 a1 PPTXWPDI SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson P -R Sheriff t it (� se Jody S Smith 1�ON T Chief Deputy 1013 JUN p� Richard W Stewart Solicitor - ; CUMBERLAND COUNTY NSYLVANIA Portfolio Rocovery Associates LLC c/o Blatt, Hasenmiller, Leibsker&M Case Number vs. Spenser David Leader 2012-2632 SHERIFF'S RETURN OF SERVICE 05/29/2013 01:35 PM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Teller, 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 her. The writ of execution and notice to defendant was mailed on May 30, 2013 to Spenser d. Leader at 221 N 2nd Street, Wormleysburg, PA 17043. SHERIFF COST: $86.99 SO ANSWERS, June 20, 2013 RONR ANDERSON, SHERIFF i,�i C:ou^ty3u. .3h nf', A . A{ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ti .. t Sheriff ° I_,- �S t, Jody S Smith t,,, t'" THE �� 1t o.r dr r • Chief Deputy 2013 DEC —9 PM 3: 44 Richard W Stewart ",, *.� OFFICE �: � CUMBERL,4I' L1 COUNTY Solicitor PENNSYLVANIA Portfolio Rocovery Associates LLC c/o Blatt, Hasenmiller, Leibsker&M vs. Case Number Spenser David Leader 2012-2632 SHERIFF'S RETURN OF SERVICE 05/29/2013 01:35 PM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Julie Myers, Teller, 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 her. The writ of execution and notice to defendant was mailed on May 30, 2013 to Spenser d. Leader at 221 N 2nd Street, Wormleysburg, PA 17043. 12/06/2013 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: $89.66 SO ANSWERS, December 06, 2013 RON� R ANDERSON, SHERIFF . , De ., -a Pt LjZ,, f 4/55 4141 29c9-39 c?CountySuite Sheriff,Teleosoft,liic. • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) .1- NO 12-2632 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PORTFOLIO RECOVERY ASSOCIATES LLC C/O BLATT,HASENMILLER,LEIBSKER& MOORE,LLC Plaintiff(s) From SPENCER D. LEADER,221 N 2ND STREET,LEMOYNE,PA 17043 (1) You are directed to levy upon the property of the defendant(s)and to sell 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, 1300 CAMP HILL BYP,CAMP HILL,PA 17011 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; (2) 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$471.63 Plaintiff Paid$ Interest FROM 4/30/12-$7.06 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ n Date: 5/22/13 . 211. David D. Buell,Prothonotary (`,;euU) _ • ! . Deputy REQUESTING PARTY: Name : MORRIS SCOTT,ESQUIRE Address: BLATT,HASENMILLER,LEIBSKER&MOORE,LLC 1835 MARKET STREET,SUITE 501 PHILADELPHIA,PA 19103 Attorney for:PLAINTIFF Telephone: 215-564-1567 • Supreme Court ID No. 83587 TRUE COPY FROM RECORD In Testimony whereof,I here unto set my hand and the seal of said Co rt at Carlisle,Pa. This_.e 4ay of 20/.S Prothonotary -pi-106 I a. 4"" �)