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HomeMy WebLinkAbout13-0254.. ~ { a _ 1J ~_ it ~` {,_ ~ {,~ ": Andrew Sklar, Esquire (ID#65332) -,~ ~ `~~ ~~~'fl~~~~~~}"~~ Lloyd S. Markind, Esquire (ID #52507) ~~ ~ ~ ~~~ ~ ~ P~ z: ~ ~ Jordan W. Felzer, Esquire (ID #38670) Sklar - Markind C~1I~~Ef~~.,4ND COUNTY 102 Browning Ln, Bldg B, Ste 1 PEi'~HSYL~~~~~ Cherry Hill NJ 08003 856/616-8710 FILE NO.: FT 1103 84 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW __ FORD MOTOR CREDIT COMPANY ~ ~ No. 06-1174 Plaintiff(s) I I Term I v. ~ ~ CIVIL ACTION WALTER A CRUSEY ~ 2 wl/ 10147 CARDINAL DRIVE ~ ~~J ~~~ ORRSTOWN PA 17244 ~ I Defendant(s) ~ I I I PRAECIPE TO ISSUE WRIT OF REVIVAL OF JUDGMENT To the Prothonotary: Issue writ of revival of judgment in the above-entitled cause and index it in the judgment index against: WALTER A CRUSEY, Defendant(s) in the amount of $9,185.62 with interest from January 7, 2008. SKI~R O Date: December 28, 2012 S Q ~~~ ~~ . S4 3 O,~ a ~ (r u 55•So``u ao "" I `-(. c~ t fig. 3~ V /1J~-f ~ \ Andrew Sklar, Esquire (ID #65332) Lloyd S. Markind, Esquire (ID$52507) Jordan W. Felzer, Esquire (ID #38670) Attorneys for Plaintiff $a as ~~ x.102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 c~~ $a37 856/616-8710 f \ ,~ ~ ~~ ~r~~ (~- f) u ~? 7th ail ~e ~ ll 1 t L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Vs. WALTER A. CRUSEY 10147 CARDINAL DRIVE ORRSTOWN, PA 17244 TO: WALTER A. CRUSEY CIVIL ACTION LAW No 13-254 CIVIL TERM WRIT OF REVIVAL You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the judgment entered to No. 06-1174 Civil Term The Plaintiff claims that the amount due and unpaid is $9,185.62 with interest from JANUARY 7, 2008. You are required within twenty (20) days after service of this Writ to file an answer or otherwise, plead to this Writ, If you fail to do so, Judgment of revival will be entered. Costs $ 188.34 PD ATTY $ 2.25 DUE CO Date 1 i 15/20l 3 (Sean ANDREW SKLAR, ESQUIRE, ID# 65332 Attorney for the Plaintiff SKLAR- MARKIND 102 Browning Lane, Bldg B., Suite 1 Cherry Hill, NJ 08003 856-616-8710 David D. Buell, Prothonotary ,~ _ - Deputy Lloyd S. Markind,Esquire(ID#52507) Jordan W.Felzer,Esquire(ID 938670) Sklar—Markind 102 Browning Lane,Building B, Suite I Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FTI 10384 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION -LAW 7- FORD MOTOR CREDIT COMPANY : No. 13-254 Plaintiff TERM VS. p C7 C1 CIVIL ACTION WALTER A CRUSEY r'3 Defendant CO PRAECIPE TO ENTER DEFAULT JUDGMENT(REVIVAL) TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, FORD MOTOR CREDIT COMPANY and against Defendant(s), WALTER A CRUSEY ,for failure to answer or otherwise respond to the Writ of Revival. 1. The Writ of Revival was served upon defendant(s)on by Sheriff. A copy of the Proof of Service is attached hereto as Exhibit A. 2. A Notice Praecipe to Enter Default Judgment was served upon Defendant(s) by regular mail on JULY 12,2013. 3. A copy of the Notice is attached hereto as Exhibit B. A copy of the Certification of Service of the Notice is attached hereto as Exhibit C. Pursuant to the Notice,Defendant(s) had 10 days in which to answer the Writ of Revival. The ten(10)days expired on JULY 22,2013. Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a Revival of Judgment has been entered against you in the above proceeding as indicated below. Assess damages in the principal amount of$9,185.62,being the amount demanded in the Writ of Revival,together with interest and costs of this action. SKLAR— ARKIND Lloyd S. Markind, Esquire(ID 452507) Jordan W. Felzer,Esquire(ID#38670) ATTORNEY FOR PLAINTIFF Date: a� c2q vAs rV 0 fI d 4141 k4d ' Lloyd S.Markind,Esquire(ID#52507) Sklar—Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FT110384 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW (Rule of Civil Procedure No. 236)Revised FORD MOTOR CREDIT COMPANY : No, 13-254 Plaintiff TERM VS. CIVIL ACTION WALTER A CRUSEY Defendant CERTIFICATION OF NON-MILITrARY SERVICE Lloyd S. Markind,Esquire,hereby certifies and says that he is the attorney for the plaintiff;that he is authorized to make this certification on behalf of plaintiff;that the above-named defendants WALTER A CRUSEY reside(s)at 3650 VARTAN WAY,HARRISBURG PA 17110-9438;and that the defendant(s)WALTER A CRUSEY is/are not in the Military Service of the United States, nor any.State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. Affidavit also certifies that the address of the plaintiff is 1335 S.Clearview Avenue,Mesa,AZ, 85209. I verify that the foregoing statement of facts 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.A.4904 relating to unsworn falsifications to authorities. SKLAR—MARKIND Lloyd S. Markind,Esquire(11)#52507) ATTORNEY FOR PLAINTIFF Date: Exhibit A SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson slr�rtlf , �arWa of G�r+�fl�tyM , Jody S Smith Chief Deputy ;;+ : Richard W Stewartta Solicitor Offacrr Of r+Ef 51-Qmr Ford Motor Credit Company Case Number VS. 2013-254 Walter Crusey SHERIFF'S RETURN OF SERVICE D111812013 Sheriff Ronny R Anderson, being duty sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit:Walter A Crusey, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Writ of Revival according to law. 02/0112013 01:23 PM-The requested Writ of Revival served by the Sheriff of Franklin County upon Waiter A Crusey, personally, at 10147 Cardinal drive, Orrstoarn,PA 17244.Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST:$37.45 SO ANSWERS, February 11,2013 RbNrV R ANDERSON, SHERIFF t�:cwnrsdte s+,Em,Teem ina SHERIFF'S RETURN - REGULAR CASE NO: 2013-00021 T COMMONWEALTH OF PMqNSYLV TI.A: COUNTY OF FRANKLIN FORD MOTOR CREDIT C014PANY VS WALTER A CRUSEY ANGEL L LAVIBN2k € Deputy Sheriff of FRkNKLIN County, Pennsylvania, who being duly sworn. according to law,. says, the .within 'MAST OF REVIVAL was served uDoan CRUSEY WALTER A the DEFENDANT , at 1323 :0 Hour,, on the 1st day of February , 2013 at FRANKLIN COUNTY SHERIFF'S OFFI CRAMBERSBUR.G, PA 17201 by handing to WALTER A CRUSEY , a true and attested copy of WRIT OF REVIVAL together with, and at the sane time directing His atter.;tion to the contents thereof. Sheriff' s Costs: sca Axnswers Docketing 100 Service .00 ANGEL L Alf idavit .00 Surcharge .00 By . 00 ffTputy Sheriff .00 02/06/2013 ANDREW .SKLAR ESQ Sworn arid Subscribed to before me this 9 day of COMMO% I THOFPENNSY1.VOIA f/3 A.D, D.tu4cC�+ `t NOtsty�FUW i21Ct`tARt� r ohmbersbUM ff�S V)d 'fig, 1 t ty J �j $y 00MmK s �V tQ. Exhibit B Lloyd S.Markind,Esquire(]D#52507) Amy F. Doyle,Esquire.(ID#87062). Jordan W. Felzer,Esquire(ID#38670) Sklar—Markind 102 Browning Ln,Bldg B,Ste I Cherry Hill NJ 08003 (856)616.8710 Attorney for Plaintiff File No.: FT110384 IN THE COURT OF COMMON PLEAS OF CUMBERLAN15 COUNTY,PENNSYLVANIA CIVIL ACTION-LAW (Rule of Civil Procedure No.236)Revised FORD MOTOR CREDIT COMPANY No. 13-254 Plaintiff TERM VS. CIVIL ACTION WALTER A CRUSEY Defendant NOTICE OF INTENTION TO TAKE DEFAULT TO: WALTER A CkUSEY 3650 VARIAN WAY HARRISBURG PA 17110-9438 DATE OF NOTICE:July 12,2013 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(10)days from the date of this notice as set forth above,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD ST CARLISLE,PA 0013 717/249-3166 R—MARI�� Lloyd S.Markind,Esquire Amy F.Doyle,Esquire Jordan W.Felzer,Esquire Attorneys for Plaintiff Disclosure You are hereby advised,pursuant to the Fair Debt Collection Practices Act,that this firm is deemed to be a debt collector attempting to collect a debt and any information obtained will be used for that purpose. SKLAR-MARKIND y�� PQST� _ 1.02 BROWNING IN, BLDG B, STE I CHERRY HILL,NJ 08003 / ` PI-Twev SOw£5 ADDRESS SERVICE REQUESTED 02 I P $ 000.46° 0003155574 JUL 12 2013 MAILED FROM ZIP CODE 08034 WALTER A CRUSEY 3650 VARTAN WAY HARRISBURG PA 17110-9438 Exhibit C Lloyd S. Markind, Esquire(ID#52507) Jordan W. Felzer, Esquire(ID 438670) Sklar—Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FT110384 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW (Rule of Civil Procedure No. 236)Revised FORD MOTOR CREDIT COMPANY : No. 13-254 Plaintiff VS. TERM CIVIL ACTION WALTER A CRUSEY Defendant CERTIFICATION PURSUANT TO Pa. R.C.P. 237 The undersigned hereby certifies that on JULY 12, 2013 1 mailed a true and correct copy by regular mail, of NOTICE OF INTENTION TO TAKE DEFAULT to: WALTER A CRUSEY 3650 VARTAN WAY HARRISBURG PA 17110-9438 I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. SKLAR—MARKIND Lloyd S. Markind, Esquire(ID#52507) Jordan W. Felzer,Esquire(ID 438670) ATTORNEY FOR PLAINTIFF