HomeMy WebLinkAbout05-2145
APOTHAKER & ASSOCIATES, P.e.
BY: David J. Apothaker
Attorney LD.#38423
1341 N. Delaware Avenue, Suite 405
Philadelphia, PA 19125
(800) 672-0215
Attorneys for Plaintiff
PORTFOLIO RECOVERY
ASSOCIATES, LLC
120 CORPORATE BLVD STElOO
NORFOLK, VA 23502
Plaintiff,
vs.
MICHELLE SHUPP
102 E MAIN ST APT 5
MECHANICSBURG P A 17055
Defendant.
) COURT OF COMMON PLEAS
) CUMBERLAND COUNTY
)
)
)
)
)
)
)
)
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P.5-.:2./<f;:,
NO.:
NOTICE
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You have been sued in court. If you wish to defend against the claims set forth in the following pa es, you
must take action with twenty (20) days after this complaint and notice are served, by entering a written ap arance
personally or by attorney and filing in writing with the court your defenses or objections to the claims t forth
against you. You are warned that if you fail to do so the case my proceed without you and a judgment y be
entered against you by the court without further notice for any money claimed in the complaint or for any oth r claim
or relief requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONE. IF YOU DO NOT
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BEL
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral and Information Service
800-990-9108
A VISO
Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuest s en las
paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificaci n. Hace
falta asentar una comparencia escrita 0 con un abogado v entregar a la corte en forma escrita sus objeci es alas
demandas en contra de su persona. Sea avisado que 5i listed no se defiende, la corte tomara medidas y puede
continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a avor del
edemandante y requiere que usted compIa con todas las provisiones de esta demanda. Usted puede perde dinero 0
sus propiedades U otros derechos importantes pare usted.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOG
NO TlENE EL DINERO SUFICIENTE DE PAGAR TAL SERVrCIO. VAYA EN PERSONA 0 LL
TELEFONO A LA OFICINA CUYA DIRECCrON SE ENCUENTRA ESCRITA ABAJO PARA AV
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
Lawyer Referral and Information Service
800-990-9108
DO 0 SI
E POR
GUAR
...
APOTHAKER & ASSOCIATES, P.e.
BY: David J. Apothaker
Attorney LD.#38423
1341 N. Delaware Avenue, Suite 405
Philadelphia, PA 19125
(800) 672-0215
Attorneys for Plaintiff
PORTFOLIO RECOVERY
ASSOCIATES, LLC
120 CORPORATE BLVD STEI 00
NORFOLK, VA 23502
Plaintiff,
) COURT OF COMMON PLEAS
) CUMBERLAND COUNTY
)
)
)
)
)
)
)
)
)
NO.:
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vs.
MICHELLE SHUPP
102 E MAIN ST APT 5
MECHANICSBURG P A 17055
Defendant.
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is a company ith its
principal place of business located at 120 CORPORATE BLVD STE100 NORFOL , VA
23502.
2. Defendant is MICHELLE SU SHUPP, an adult individual residing at 102 E
MAIN ST APT 5 MECHANICSBURG P A 17055.
3. At the special instance and request of Defendant, Plaintiff sold and deli ered to
Defendant goods and/or services at the times, of the kinds, in the quantities, and for the p 'ces set
forth in Plaintiffs records. A tme and correct copy of which is attached hereto, incOlporat herein
by reference and designated Exhibit "A".
4. Defendant received and accepted the goods and/or services described i Exhibit
"A".
5. The prices set forth in Exhibit "A" are the fair, reasonable and market price for said
goods and/or services, and the prices which Defendant agreed to pay.
6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A".
7. In addition, Plaintiff avers that Defendant has failed and continues to fail to ake
any payments, leaving a balance due and owing of $13,671.l4 together with interest om
December 1,2003 in the amount of$1,093.76.
8. Although demand has been made, Defendant has failed to make payment f the
amount due as above.
9. The original creditor is FLEET NATIONAL BANK.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defen antes)
for the sum of $13,671.14 together with interest from December 1, 2003 in the amo t of
$1,093.76, plus costs, interest and reasonable attorney's fees.
APOTHAKER & ASSOCIATES, P.e.
Attorney for Plaintiff
BY:
Dated: Apri115, 2005
Our File No.: 0501185
VERIFICATION
David J. Apothaker, ESQ. hereby states that I am counsel for plaintiff in this action, and that am
authorized to take this Verification, and that the statements made in the foregoing Civil tion
Complaint are true and correct to the best of my knowledge, information, and belief. The
undersigned understands that the statements therein are made subject to the penalties f 18
Pa.C.S.A. 4904 relating to unsworn falsification to authorities.
David J. Apothaker, Esq.
Attorney for Plaintiff
DATE: April 15, 2005
PORTFOLIO RECOVERY ASSOC.
120 CORPORATE BLVD STEIOO
NORFOLK, VA, 23502
MICHELLE SHUPP
102 E MAIN ST APT 5
MECHANICSBURG PA 17055
STATEMENT OF ACCOUNT
Debtor's Name:
MICHELLE SHUPP
Account Number:
20924355
Original Creditor:
FLEET NATIONAL BANK
Date of Debt:
December 1, 2003
Principal Balance:
$13,671.14
Balance Due:
$13,671.14
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SHERIFF'S RETURN - REGULAR
CASE NO: 2005-02145 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PORTFOLIO RECOVERY ASSOCIATES
VS
SHUPP MICHELLE
GERALD WORTHINGTON
Sheriff or Deputy Sheriff of
Cumberland County, pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
SHUPP MICHELLE
the
DEFENDANT
, at 1933:00 HOURS, on the 9th day of May
2005
at 102 E MAIN STREET
APT 5
MECHANICSBURG, PA 17055
by handing to
MICHELLE SHUPP
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
18.00
7.40
.37
10.00
.00
35.77
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R. Thomas Kline
05/10/2005
APOTHAKER & ASSOCIATES
Sworn and Subscribed to before
me this liE-
day of
By: ~
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MJ"O';;~"/:I{
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. ~rothonotary , ~
A.D.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Portfolio Recovery Associates, LLC
Plaintiff
v.
No. 05-2145 Civil
Michelle Shupp
Defendant
PETITION TO STRIKE. OR IN THE ALTERNATIVE. OPEN DEFAULT JUDGMENT
Defendant Michelle Shupp, pro se, respectfully petitions the Court to open and/or
strike the default judgment entered on August 7,2006. In support, Defendant states as
follows:
Petition to Strike
1. The default judgment was improperly entered. Defendant did not receive the
required notice of intention to take default, and the notice of intention to take judgment by
default attached to Plaintiff's Praecipe to Enter Default Judgment does not contain a
certificate of service reflecting service of the notice upon Defendant.
2. Defendant therefore avers that no notice was served by Plaintiff as required
for the entry of default.
3. Additionally, Plaintiff agreed to extend the time for Defendant to answer, such
that no answer would be due until October 1, 2007. See June 17, 2005 letter attached as
an Exhibit hereto (letter from Defendant's former counsel confirming agreement to extend
time). Defendant has been making payments to Plaintiff pursuant to the terms of Exhibit A.
Plaintiff has not given Defendant any notice of late payment that Defendant has not
corrected. As such, Plaintiff improperly entered judgment by default.
WHEREFORE, Defendant requests that the Default Judgment be stricken.
....J
...
Petition to Open
4. In the alternative, Defendant requests that the Court open the Default
Juqgment.
5. This Petition to Open is filed within 10 days of entry of the Default Judgment.
6. Defendant has a reasonable excuse for the delay in answering, namely that
thE:! parties agreed to extend the time for answering until October 1, 2007. See Exhibit
attached hereto
6. Defendant has a meritorious defense to the Complaint, in that the parties
agreed to a settlement of Plaintiff's claims against Defendant.
7. Defendant is not in breach of the settlement agreement with Plaintiff and has
been making payments pursuant thereto.
8. Attached hereto is the verified answer that Defendant seeks leave to file if the
judgment is opened.
WHEREFORE, if the default judgment is not stricken, Defendant requests that the
judgment be opened.
August lfe, 2006
2
-
.
VERIFICA liON
Subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to
authorities, I have reviewed the foregoing petition and the facts set forth therein are true and
correct to the best of my knowledge, information and belief.
Dated: August\k, 2006
'AVfr
McNees Wallace & Nurick LLC
attorneys at law
HELEN L. GEMMILL
DIRECT DIAL: (717) 237-5273
E-MAIL ADDRESS:HGEMMILL@MWN.COM
June 17, 2005
BY FAX
Elaine Thomas
Apothaker & Associates, P .C.
Suite 405
1341 N. Delaware Avenue
Philadelphia, PA 19125
RE: Portfolio Recovery Associates, LLC v. Michelle Shupp
Cumberland County C.P. No. 05-2145 Civil
Dear Ms. Thomas:
Thank you for your cooperation in establishing a payment plan for the payment of
the sum of $14,830.41. Per our discussion, payments will be made as follows:
. Eleven monthly payments of $125 - paid on the 1st of the month for July 2005
through May 2006 (total of $1375);
· Sixteen monthly payments of $475 - paid on the 1st of the month for June 2006
though September 2007 (total of $7600);
· Lump sum payment of $600 on September 1, 2005;
· Lump sum payment of $3000 on September 1, 2006;
· Lump sum payment of $2000 on September 1,2007;
· Final payment of $255.41 on October 1, 2007.
Additionally, we are willing to enter into a stipulated judgment. The stipulated
judgment would be filed with the court only if Ms. Shupp missed a payment, and the missed
payment was not tendered within ten days after notice from your client that the payment
was not received. In the meantime, the case would remain pending in the court (although
we would have an extension until October 1,2007 to file any response to the complaint).
Upon receipt of the final payment, you would dismiss the lawsuit with prejudice.
Please confirm that this letter reflects the terms of our agreement.
Sincerely,
McNEES WALLACE & NURICK LLC
By
I/-L [ . {;-J,O
Helen L. Gemmill
c: Michelle Shupp
PO. Box 1166.100 PINE STREET. HARRISBURG, PA 17108-1166 . TEL: 717.232.8000. FAX: 717.237.5300. WWW.MWN.COM
HAZLETON, PA' LANCASTER, PA. STATE COLLEGE, PA. COLUMBUS, OH . WASHINGTON, DC
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APOTHAKER & ASSOCIATES, P.e.
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
(215) 634-8920
Attorneys for Plaintiff
David 1. Apothaker, Esquire
Attorney ID #38423
Plaintiff,
) COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
)
)
) NO.: 05-2145
)
) Civil Action
)
)
PORTFOLIO RECOVERY
ASSOCIATES, LLC
vs.
MICHELLE SU SHUPP
Defendant.
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a default judgment in favor of plaintiff, PORTFOLIO RECOVERY ASSOCIATES,
LLC and against Defendant, MICHELLE SU SHUPP, for failure to answer or otherwise respond to the
Complaint - Civil Action.
The Complaint was served upon the defendants on May 9, 2005 by the CUMBERLAND
Sheriffs Department. Copies of the proofs of service are attached hereto as Exhibit "A".
I certify, a copy of the Notice of Intention To Take Default was mailed on December 8, 2005,
and also attached hereto.
.
.
Assess damages in the amount of:
(a) Balance:
TOTAL
$13,671.14
$ 1,093.76
$ 2,100.00
$12,664.90
(b) Interest from December 0 I, 2003
Minus payments of
APOTHAKER OCIATES, P.C.
Atto ys fo Plaintiff
By:
David J. Apothaker
Dated: July 27, 2006
Our File No.: 54236
.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: MICHELLE SU SHUPP
317 WEST MAIN STREET 2ND FL
MECHANICSBURG, P A 17055
PORTFOLIO RECOVERY
ASSOCIATES, LLC
Plaintiff,
) COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
)
)
) NO.: 05-2145
)
) Civil Action
)
)
)
vs.
MICHELLE SU SHUPP
Defendant.
NOTICE
Pursuant to Rille 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.
xx JUDGMENT BY DEFAULT
JUDGMENT IN REPLEVIN
JUDGMENT BY CONFESSION
JUDGMENT FOR POSSESSION
JUDGMENT ON AWARD OF ARBITRATORS
JUDGMENT ON VERDICT
JUDGMENT ON COURT FINDINGS
JUDGMENT ON WRIT OF REVIVAL
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY David J. Apothaker. ESQ. at this telephone number: 215-634-8920
.
.
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker
Attorney I.D.#38423
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
(215) 634-8920
Attorney for Plaintiff
PORTFOLIO RECOVERY
ASSOCIATES, LLC
Plaintiff,
) COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
)
)
) NO.: 05-2145
)
) Civil Action
)
)
)
vs.
MICHELLE SU SHUPP
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYL VANIA
SS.
COUNTY OF CUMBERLAND
David 1. Apothaker, being duly sworn according to law, deposes and says that I am the attorney
for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 317 WEST MAIN
STREET 2ND FL MECHANICSBURG, PA 17055; and that Defendant(s) is 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 amendments eret.
David 1. pothaker
Attorney for Plaintiff
The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S.
Section 4904 relating to unsworn falsification to authorities.
.
CASE NO: 2005-02145 P
.
SHERIFF'S RETURN - REGULAR
DStJ II ts
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PORTFOLIO RECOVERY ASSOCIATES
v~~~nlYl~~
fl MAY 1 3 2005 W,
By 6~ll ~5
VS
SHUPP MICHELLE
GERALD WORTHINGTON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
SHUPP MICHELLE
the
DEFENDANT
, at 1933:00 HOURS, on the 9th day of May
,~
at 102 E MAIN STREET
APT 5
MECHANICSBURG, PA 17055
MICHELLE SHUPP
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Postage
Surcharge
So Answers:
l~:~g .~~ ~
.37 f ' 1'~
10.00 R. Thomas Kline
.00
35.77 05/10/2005
APOTHAKER & ASSOCIATES
Sworn and Subscribed to before
day of
By' ~
~..lil,
Deputy S iff
me this
A.D.
Prothonotary
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker
Attorney I.D.#38423
1341 N. Delaware Avenue, Suite 405
Philadelphia, PA 19125
(2 I 5) 634-8920
Attorney for Plaintiff
PORTFOLIO RECOVERY
ASSOCIATES, LLC
120 CORPORATE BLVD STEI00
NORFOLK, VA 23502
Plaintiff,
vs.
MICHELLE SU SHUPP
102 E MAIN ST
MECHANICSBURG PA 17055
Defendant.
TO: MICHELLE SU SHUPP
DATE OF NOTICE: December 8,2005
) COURT OF COMMON PLEAS
) CUMBERLAND COUNTY
)
)
)
) NO. 05.2145
)
)
)
)
)
NOTICE OF INTENTION
TO TAKE DEFAULT
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
Lawyer Referral and Information Service
800-990-9108
DAVID~' ESQUIRE
1341 N. Delaware Avenue, Suite 405
Philadelphia, PA 19125
(800) 672-0215
Attorney for Plaintiff
Attorney ill #38423
Our File No.: 0501185
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Portfolio Recovery Associates, LLC
Plaintiff
v.
No. 05-2145 Civil
Michelle Shupp
Defendant
ANSWER WITH NEW MATTER
Defendant Michelle Shupp, pro se, for her answer and new matter, states as follows:
Answer
1. Upon reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of this averment and therefore denies
the averment.
2. Denied. Defendant's current address is 317 W. Main Street, 2nd Floor,
Mechanicsburg, PA 17055.
3. Upon reasonable investigation, Defendant is without knowledge or
information sufficient to form a belief as to the truth of this averment and therefore denies
the averment. Further answering, Plaintiff is not the credit card company used by
Defendant. Defendant has only been informed that there is a connection between Plaintiff
and the credit card company.
4. Admitted upon information and belief.
5. Admitted upon information and belief.
6. Admitted upon information and belief.
7. Denied. Further answering, Plaintiff and Defendant entered into a settlement
agreement of all claims asserted in this action. Defendant has been making payments
~'.
under the settlement agreement and is not in breach of the settlement agreement. See
Exhibit attached hereto (letter dated June 17, 2005).
8. Denied. Further answering, Plaintiff and Defendant entered into a settlement
agreement of all claims asserted in this action. Defendant has been making payments
under the settlement agreement and is not in breach of the settlement agreement. See
Exhibit attached hereto (letter dated June 17, 2005).
9. Admitted upon information and belief.
WHEREFORE, Defendant request judgment in favor of Defendant and against
Plaintiff.
New Matter
10. Plaintiff and Defendant entered into a settlement agreement of all claims
asserted in this action.
11. Defendant has been making payments under the settlement agreement and
is not in breach of the settlement agreement. See Exhibit attached hereto (letter dated June
H, 2005).
WHEREFORE, Defendant request judgment in favor of Defendant and against
Plaintiff.
,
i elle Shupp, 0
317 W. Main Street, nd Floor
Mechanicsburg, PA 17055
(717) 877-2284
August /IP, 2006
2
...
VERIFICATION
Subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to
authorities, I have reviewed the foregoing answer and the facts set forth therein are true and
correct to the best of my knowledge, information and belief.
tlJ.f{M
. Michelle S pp
Dated: August 1fe., 2006
3
. ...
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing was served by first class mail,
postage prepaid on the date below, address as follows:
David J. Apothaker
Apothaker & Associates, P .C.
1341 N. Delaware Ave., Suite 405
Philadelphia, PA 19125
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August/.k., 2006
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
AUG 1 8 2006 (
Portfolio Recovery Associates, LLC
Plaintiff
v.
No. 05-2145 Civil
Michelle Shupp
Defendant
ORDER
AND NOW, this ~ day of ~ ~o ~ upon consideration of the
foregoing petition, it is hereby ordered that:
(1) a rule is issued upon the respondent to show cause why the petitioner is not
entitled to the relief requested;
(2) the respondent shall file an answer to the petition within :1-0 days of this
date;
(3) the petition shall be decided under Pa.R.C.P. No. 206.,7
'If t.,,,",
(4) depositions ^shall be completed within 4' days of this date;
(5) argument shall be held on @(!:i; ~ "a06" in Courtroom 'f of the
j1h~I1A?~County Courthouse; ~ dll 00 fJ. m ·
(6) notice of the entry of this order shall be provided to all parties by the
petitioner.
BY THE COURT:
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PORTFOLIO RECOVERY,
ASSOCIATES, LLC,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V
CIVIL ACTION - LAW
MICHELLE SHUPP,
Defendant
NO. 05-2145 CIVIL
IN RE: PETITION TO STRIKE OR IN THE ALTERNATIVE
OPEN DEFAULT JUDGMENT
ORDER OF COURT
AND NOW, this 26th day of October, 2006, in accordance
with the stipulation of the parties entered into of even date
herewith, the Petition to Strike or in the Alternative Open
Default Judgment is granted, and said judgment is stricken.
By the Court,
~mberlY F. Scian, Esquire
520 Fellowship Road C306
Mount Laurel, New Jersey 08054
For Plaintiff
#L
Hess, J.
~ Michelle Shupp
317 W. Main Street,
Mechanicsburg, PA
Defendant
2nd Floor
17055
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