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HomeMy WebLinkAbout13-0280R ~-- Andrew Sklaz, Esquire (ID#65332) Lloyd S. Mazkind, Esquire (ID #52507) Jordan W. Felzer, Esquire (ID #38670) Sklaz - Mazkind 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 856/616-8710 FILE NO.: FT110121 Attorneys for Plaintiff f' ~~ 1. ~~~~(~.'~ ~4j •- ''~ ~~~ r~„~ ~~{t Q1V~ TAB ~ 2013,IAN 16 PM 3r 52 ~~ P~1`S Y ~ ~T Y [.Yq.tA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW FORD MOTOR CREDIT COMPANY I I No. 2005-03499 P Plaintiff(s) I I Term v. I CIVIL ACTION RANDI S SWEENEY I 101 POPLAR RD I New Cumberland PA 17070-3427 I I Defendant(s) I 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: RANDI S SWEENEY, Defendant(s) in the amount of $5,082.62 with interest from September 8, 2005. Date: January 7, 2013 k~~~~ ~ "~ SS,S~ ;~„ ~ . ~bo ~a a~ 116 ~~~' S Andre Sklaz, Esquire (ID #65332) Lloyd S. Mazkind, Esquire (ID$52507) Jordan W. Felzer, Esquire (ID #38670) aS ~ ~, Attorneys for Plaintiff ~,,~- 102 Browning Ln, Bldg B, Ste 1 Cherry Hill NJ 08003 ~~~ ~1~5 856/616-8710 / I ~ 1,,- , ~ ~ ~ hn ~ i T~Sr~c° r( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY Vs. RANDI S. SWEENEY 101 POPLAR ROAD NEW CUMBERLAND, PA 17070 CIVIL ACTION LAW No 13-280 CIVIL TERM WRIT OF REVIVAL TO: RANDI S. SWEENEY You are notified that the Plaintiff has commenced a proceeding to revive and continue the lien of the j udgment entered to No. OS-3499 Civil Term The Plaintiff claims that the amount due and unpaid is $5,082.62 with interest from SEPTEMBER 8, 2005. 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 $ 134.00 PD ATTY $ 2.25 DUE CO David D. Buell, Prothonotary Date 1 / 16/2013 Deputy (Seal) ANDREW SKLAR, ESQUIRE, ID#65332 Attorney for the Plaintiff SKLAR- MARKIND 102 Browning Lane, Building B., Suite 1 Cherry Hill, NJ 08003 856-616-8710 Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer, Esquire(ID#38670) Sklar—Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FT 110121 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW n FORD MOTOR CREDIT COMPANY : No. 13-280 civil � Plaintiff r£'� TERM (Dr- - vs. a C) �C:, CIVIL ACTION < -0 CD 0 CD r RANDI S SWEENEY _=ter CD Defendant PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, FORD MOTOR CREDIT COMPANY , and against Defendant,RANDI S SWEENEY , for failure to answer or otherwise respond to the Complaint. 1. The Complaint was served upon defendant on by Sheriff. A copy of the Proof of Service is attached hereto as 2. A Notice Praecipe to Enter Default Judgment was served upon Defendant by regular mail on MARCH 22, 2013. 3. A copy of the Notice is attached hereto as-=##FrE. A copy of the Certification of Service of the Notice is attached hereto ash. Pursuant to the Notice, Defendant had 10 days in which to answer the Complaint. The ten (10) days expired on APRIL 2, 2013. Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Assess damages in the principal amount of$5,082.62, being the amount demanded in the Writ of Revival in the amount of $$5,082.62, together with costs of this action. (Zi!c SKLAR— f�ATD Lloyd S. Markind, Esquire(ID#52507) Jordan W. Felzer, Esquire(ID #38670) ATTORNEY FOR PLAINTIFF Date: owl PcItt-K SKLAR-MARKIND 4 QUO a - _ �e imt 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.: FT110121 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. 13-280 civil Plaintiff TERM vs. CIVIL ACTION RANDI S SWEENEY Defendant CERTIFICATION OF NON-MILITARY 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 RANDI S SWEENEY reside(s)at 101 POPLAR RD, New Cumberland PA 17070-3427; and that the defendant(s)RANDI S SWEENEY 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 1.8 PA. C.S.A. 4904 relating to unsworn falsifications to authorities. SKLAR---MARKIND Lloyd S. Markind, Esquire (ID#52507) Date: r ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW FORD MOTOR CREDIT COMPANY : No. 2005-03499 P Plaintiff TERM vs. CIVIL ACTION RANDI S SWEENEY Defendant j CERTIFICATION OF SERVICE/COMPLIANCE -HEAT HERMINYE, of full age,hereby certifies as follows: 1. 1 am a paralegal employed with the SKLAR—MARKIND. 2. On 2,12,5 1 served copies of the filed Praecipe to Issue Writ of Revival of Judgment and Writ of Revival of Judgment on defendant(s), RANDI S SWEENEY ,by sending them simultaneously by regular and certified mail,return receipt requested to: RANDI S SWEENEY 101 POPLAR RD New Cumberland PA 17070-3427 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—a—m subject to punishment. Dated: File No.: FT110121 Andrew Sklar,Esquire(ID#65332) Lloyd S.Markind,Esquire(ID#52507) Jordan W. Felzer,Esquire(ID 438670) Sklar—Markind 102 Browning Ln,Bldg B,Ste I Cherry Hill NJ 08003 (856)616-8710 Attorney for Plaintiff File No,: FT110121 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. 2005-03499 P Plaintiff TERM VS. CIVIL ACTION RANDI S SWEENEY Defendant NOTICE OF INTENTION TO TAKE DEFAULT TO: RANDI S SWEENEY 101 POPLAR RD New Cumberland PA 17070-3427 DATE OF NOTICE: March 22,2013 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 17013 717/249-3166 MARr"t5-, Andrew Sklar,Esquire Lloyd S.Markind,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 ri<cs PCST,S,T 102 BROWNING LN, BLDG B, STE 1 `M^� :r � , CHERRY HILL, NJ 08003 t "� An -N r C` r + � fit's N ADDRESS SERVICE REQUESTED x� PtTH;Y 60wE5 0� 1:P S $ 000.46 °� 1- - 00031 55574 MAR 22 2113 MAILED FROM ZIP CODE 08034 RANDI S SWEENEY 101 POPLAR RD New Cumberland PA 17070-3427 1 . Lloyd S. Markind, Esquire (ID#52507) Jordan W. Felzer,Esquire (ID#38670) Sklar—Markind 102 Browning Lane, Building B, Suite I Cherry Hill, NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FT 110121 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. 13-280 civil Plaintiff TERM vs. CIVIL ACTION RANDI S SWEENEY : Defendant CERTIFICATION PURSUANT TO Pa. R.C.P. 237 The undersigned hereby certifies that on MARCH 22, 2013 1 mailed a true and correct copy by regular mail, of NOTICE OF INTENTION TO TAKE DEFAULT to: RANDI S SWEENEY 101 POPLAR RD New Cumberland PA 17070-3427 1 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#38670) ATTORNEY FOR PLAINTIFF 0 Lloyd S. Markind, Esquire(ID#52507) Jordan W. Felzer,Esquire(ID#38670) Sklar—Markind 102 Browning Lane, Building B, Suite 1 Cherry Hill,NJ 08003 856-616-8710 Attorneys for Plaintiff FILE NO.: FT110121 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION-LAW FORD MOTOR CREDIT COMPANY : No. 13-280 civil Plaintiff TERM vs. CIVIL ACTION RANDI S SWEENEY Defendant TO: RANDI S SWEENEY 101 POPLAR RD New Cumberland PA 17070-3427 Date: May 2, 2013 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania,you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. X Judgment by Default g Money Judgment �o��► ' Judgment in Replevin (� 2 Confession of Judgment for Possession Judgment on Award of Arbitration Judgment on Court Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY: Sklar—Markind Lloyd S. Markind,Esquire Jordan W. Felzer,Esquire at this telephone number: 856-616-8710