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Home My WebLink About07-0492IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. Ott qQ =- L? ASSIGNEE OF OPTION CART? ASSINGEE OF HOUSEHOLD BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS NJ 07632 Plaintiff VS JERRY YOUNG 25 E LISBURN RD BOWMANSDALE PA 17008 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, PALISADES COLLECTION,L.L.C. Counsel of record for this party: Date: Amy F. Doyle #87 / Daniel F. Wolfson #20617 Philip C. Warholic 6341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF OPTION CARD ASSINGEE OF HOUSEHOLD BANK Plaintiff :CIVIL ACTION - LAW VS JERRY YOUNG Defendant(s) You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 CCP Notice to Defend W&A File No. 166006571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSINGEE OF HOUSEHOLD BANK Plaintiff VS JERRY YOUNG Defendant(s) :No. :CIVIL ACTION - LAW NOTICIA USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dies despu6s que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 CCP Notice to Defend W&A File No. 166006571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CA_t'? - ASSINGEE OF HOUSEHOLD BANK Plaintiff VS JERRY YOUNG Defendant(s) :No. 0'7- Y9-2 ?- 7-,u- :CIVIL ACTION - LAW AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Wolpoff & Abramson, LLP, and files this Complaint and in support avers as follows: 1. Plaintiff is PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSINGEE OF HOUSEHOLD BANK, located at 210 Sylvan Avenue Englewood Cliffs, NJ 07632. 2. Defendant, JERRY YOUNG, is an adult individual with a last known address of 25 E Lisburn Rd Bowmansdale, Cumberland County, PA 17008. 3. It is averred that Defendant was issued an open end credit account (hereinafter "Account"). 4. At all relevant.times material hereto, Defendant has been a regular user of said Account for the purchase of products, goods and/or for obtaining services. 1 I 5. Defendant was provided with copies of the Statement of Accounts showing all debits and credits for transactions on the aforementioned credit card account to which there was no bona fide objection by Defendant. A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". 6. Defendant did not object to the above-mentioned statements submitted by Plaintiff and/or its assignors to Defendant. CCP Cmplt - WOR & AF 4 W&A File No. 166006571 7. As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant and/or any authorized users is the sum of $6,374.78. 8. Interest has accrued from the charge off date at a rate of 18 %. 9. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $3,175.67. 10. Despite reasonable and repeated demands for payment, Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 11. Plaintiff performed any and all conditions precedent to the bringing of this action. 12. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - WOR & AF 5 W&A File No. 166006571 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant in the amount of $6,374.78, plus interest in the amount of $3,175.67, plus costs of this action and any otncr rolief as this ` 5ourt deems just and reasonable. Respectfully Submitted, Date: Ilkofio 7 f1j'a ? Amy F. Doyle #87062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR & AF 6 W&A Pile No. 166006571 VERIFICATION The undersigned hereby states that they are the attorney for the Plaintiff who is located outside of this juris&ict-ica-and i .dew file the within document in an expedient and timely manfiet, drey ate"- "`--authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Pleading are true and correct to the best of their knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Date: I I (t 6 J/ 17 Amy F. Doyle #87 / Daniel F. Wolfson 402 17 Philip C. Warholic 6341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 /Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR & AF 7 W&A File No. 166006571 Exhibit "A" PLAINTIFF = 506501 ACCOUNT NUMBER = 71319700127793 POOL ID = OPTION CURRENT BALANCE = 6374.78 LSTPYMTDT = CO DATE = 20040229 DEBTOR #1 LAST NAME = YOUNG DEBTOR #1 FIRST NAME = JERRY DEBTOR #1 MIDDLE NAM = DEBTOR #1 ADDR 1 = 25 E LISBURN RD DEBTOR #1 ADDR 2 = DEBTOR #1 CITY = BOWMANSDALE DEBTOR #1 STATE = PA DEBTOR #1 ZIP = 17008 DEBTOR #1 HOMEPHONE = 0000000000 DEBTOR #1 WORKPHONE = 0000000000 DEBTOR #1 SOCSEC = DEBTOR #1 DOB = DEBTOR #2 LAST NAME _ DEBTOR #2 FIRST NAME = DEBTOR #2 MIDDLE NAM = DEBTOR #2 ADDR 1 = DEBTOR #2 ADDR 2 = DEBTOR #2 CITY = DEBTOR #2 STATE _ DEBTOR #2 ZIP = DEBTOR #2 HOMEPHONE _ DEBTOR #2 WORKPHONE _ DEBTOR # SOCSEC = DEBTOR#2 DOB = DEBTOR = 4729704 20020905 DI r" .5 r C„y C-3 --..1 i .? ?t7 O C7 'C too IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 07-492 CIVIL TERM ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff VS CIVIL ACTION - LAW JERRY YOUNG Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), JERRY YOUNG , for failure to answer the Complaint. (X) Amount due Less credits TOTAL $9,550.45 $0.00 $9,550.45, plus interest and costs ( 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 of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. (X) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: //6h"J,7?r? Amy F. Doyle #8 / D 'el F. Wolfson #20617 Philip C. Warholic #86341' David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW9 , 2067 , JUDGM NT IS?NTERJUP AS ABOVE. Proth otary ivil D' ision By: Deputy W&A File No. 166006571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. NO. 07-492 Civil Term ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff vs. CIVIL ACTION - LAW JERRY YOUNG Defendant(s) TO: JERRY YOUNG 25 E LISBURN RD BOWMANSDALE PA 17008 DATE OF NOTICE: March 06, 2007 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 ?1 Amy F. Doyle #i?062 / Daniel F. Wolfson #20617 Philip C. Warhol #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 MAIM OFFICE. TWO IRVINGTON CENTRE 702 KING FARM BLVD., ROCKVILLE, MD 20860 17 WEST CARY STRI 5122 GREENWICH RI 919 N. MARKET ST., 1 VALLEY BAN( BLDG, 4660 TRINDLE ROAD 301 GRANT ST., STE. 28832 ROADSIDE DR 39500 HIGH POINTE 1 300 CANAL VIEW SO 5216 N. O'CONNOR I? 3200 SOUTHWEST FI 111 SOLEDAD ST., S' 1201 PEACHTREE S1 301 CARLSON PKWY 4643 S. ULSTER ST., 5355 TOWN CENTER FAIRFAX. VA 22030 ONO, VA 23220 A BEACH, VA 23462 HILL, PA 17011 PA 15219 HILLS, CA 91301 r 1080, IRVING, TX 75030 STE. 3300, HOUSTON, TX 77027 kN ANTONIO, TX 78205 E. 1717, ATLANTA, GA 30361 1, MINNETONKA. MN 55305 DENVER, CO 80237 1002, BOCA RATON, FL 33486 LAW OFFICES N N ORK W 0 L P 0 F F& A B R A M S 0 N, L. L. P. OFFIC S L90TW REGIO A E F W AB Attomeys in the Practice of Debt Collection RAWIS (A National Collection Attorney Network Firm) BIRMINGHAM, ALABAMA FgRGO, NORTH DAKOTA ANCHORAGE, ALASKA 4660 TRINDLE ROAD PHOENIX, ARIZONA CLEVELAND, OHIO OKLAHOMA CITY, OKLAHOMA SUITE 300 LITTLE ROCK, ARKANSAS P EAST HARFORD, CONNECTICUT CAMP HILL PA 17011 PROVIDENCE, RHODE ISLANI , HONOLULU, HAWAII COLUMBIA, SOUTH CAROLIN BOISE, IDAHO KNOXVILLE, TENNESSEE (TOLL FREE) CHICAGO, ILLINOIS SANDY, UTAH (800) 830-2793 MERRILLVILLE, INDIANA MILWAUKEE, WISCONSIN KANSAS CITY, KANSAS RAWLINS, WYOMING FACSIMILE (866) 281-9026 LEXINGTON, KENTUCKY SEATTLE, WASHINGTON PLEASE DIRECT ALL INQUIRIES TO THE CAMP HILL OFFICE JERRY YOUNG 25 E LISBURN RD BOWMANSDALE, PA 17008 RE: PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK vs. JERRY YOUNG ' The National CoUwtlon Attorney Notwork is an ssparS% law tlr m W&A Hours of Ooeradon: 8 a.m. - 6 p.m. F W&A File No. 166006571 Dear Jerry Young: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, CN O?0' V Enclosure cc: Y March 06, 2007 Amy F. Doyl #87062 / Daniel F. Wolfson #20617 Philip C. W olic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Wolpoff & Abramson, L.L.P. Camp Hill, PA 17011 Telephone: (800) 830-2793 Counsel for Plaintiff This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD No. 07-492 CIVIL TERM ASSIGNEE OF HOUSEHOLD BANK Plaintiff VS. JERRY YOUNG Defendant(s) CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Palisades Collection,L.L.C. 210 Sylvan Avenue Englewood Cliffs NJ 07632 and certify that the last known address of the within Defendant(s) is: Jerry Young 25 E Lisburn Rd Bowmansdale PA 17008 Date: 3 as G Amy F. Doyle # 62 / D 1 F. Wolfson #20617 Philip C. Warho c #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff No. 07-492 CIVIL TERM CIVIL ACTION - LAW VS. JERRY YOUNG Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, Jerry Young, above-named, is over 21 years of age; is last known to reside at 25 E Lisburn Rd, Bowmansdale, County of Cumberland, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. 3ta Date: 3 ?4- _ Amy F. Doyle JW662 iel F. Wolfson 420617 Philip C. War olic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis # 18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 COMMONWEALTH OF PENNSYLVANIA Wolpoff & Abramson, L.L.P. Notarial sea' Attorneys in the Practice of Debt Collection Amy Wise, Notary Put Hampden T wp., Cumberland County 4660 Trindle Road, Suite 300 My Commission Expires Nov. 30, 2010 Camp Hill, PA 17011 Member, Pennsylvania Association of Notaries Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this < aaY of , 20n, yea Notary Public W&A File No. 166006571 .,? ti CI r--.,) c _ _:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff No. 07-492 Civil Term CIVIL ACTION - LAW VS. JERRY YOUNG Defendant(s) NOTICE OF JUDGMENT ( x ) Notice is hereby given t at a Judgment in the above-captioned matter has been entered against you in the amount of $9,550.45, plus interest, on 201V . ( x ) A copy of all documents filed with the Prothono . in support the within judgment is/are attached. By: If you have any questions regarding this Notice, please contact the filing arty. Date: ?j Amy F. doo le #87 / D e F olfson #20617 ijf Philip C. Warholic 86341 / avid R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Jerry Young 25 E Lisburn Rd Bowmansdale PA 17008 W&A File No. 166006571 SHERIFF'S RETURN - REGULAR CASE NO: 2007-00492 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS YOUNG JERRY VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon YOUNG JERRY the DEFENDANT at 1545:00 HOURS, on the 12th day of February , 2007 at 25 E LISBURN ROAD BOWMANSDALE, PA 17008 by handing to JERRY YOUNG a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 21.12 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 49.12 02/13/2007 a,1?.0 WOLPOFF & ABRAMSON D Sworn and Subscibed to By: before me this day Deputy She iff of A.D. L - PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff VS. JERRY YOUNG Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 07-492 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $9,550.45. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,JERRY YOUNG located at 25 E LISBURN RD APT I, MECHANICSBURG, PA 17055-5899, Defendant (s); (3) and against, MEMBERS 1ST CU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013, Garnishee (s); (4) and index this writ (a) against, JERRY YOUNG , Defendant (s) and (b) against, MEMBERS 1ST CU, Garnishee (s), as a lis pendens against the real property of the Defendant (s) in the name of the Garnishee (s) as follows: (Specifically describe property) 25 E LISBURN RD APT I MECHANICSBURG, PA 17055-5899 All personal property of any nature located within the household or immediate vicinity of the Defendant(s) address and all other personal property within the dominion and control of the Defendant(s) wherever it is located shall be subject to the levy. ALSO: You are directed to attach the property of the Defendant (s) not levied upon in the possession of MEMBERS 1 ST CU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013, Garnishee (s) 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. Amount due Interest from 4/3/2007 At an interest rate of 6% per year Date: ?4-0? $9,550.45 To Be Determined Total $9/,550.45 Plus costs & interest Amy F. D+e #87062 / Daniel F. Wolfson #20617 Phili C. W 6341 / David R. Galloway #87326 onily . C ' 8 852 / Sarah E. Ehasz #86469 Ro ert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 46601 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 XXX-XX-7896 .. L S U p 9y (? 0 _ a C..J ? ?v 00 , $ 14 U) 0 z : _ ti - 'jam 0 0 "? t N r CO t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-492 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Assignee of OPTION CARD, Assignee of HOUSEHOLD BANK, Plaintiff (s) From JERRY YOUNG, 25 E Lisburn Rd., Apt 1, Mechanicsburg, PA 17055-5899 (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property of any nature located within the household or immediate vicinity of the Defendant's address and all other personal property within the dominion and control of the Defendant wherever it is located shall be subject to the levy . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCU, 1000 Bryn Mawr Rd., Carlisle, PA 17013 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, 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 $9,550.45 L.L. $.50 Interest from 4/03/07 at an interest rate of 6% per year - To be Determined Atty's Comm % Atty Paid $145.62 Plaintiff Paid Date: 3/11/08 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs lizz1a, - Curti A. Long, Pot By: Deputy Name TONILYN M. CHIPPIE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87852 A- -V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff VS JERRY YOUNG Defendant(s) No. 07-492 CIVIL TERM CIVIL ACTION - LAW k06 46 , RECEIVED MAR 17 2008 INTERROGATORIES TO GARNISHEE TO: MEMBERS 1 ST CU 1000 BRYN MAWR RD CARLISLE, PA 17013 PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR(S). IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was issued. C. "You" means the main office and all branch offices, representatives, employees, and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, and an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. W&A File No. 166006571 XXX-XX-7896 r INTERROGATORIES TO GARNISHEE DEFENDANT(S) - JERRY YOUNG 1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository accounts with your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has in each account. If the Defendant(s) maintain any of these jointly with any other person, or persons, give their name and address. ?),`712 313 - Y * n S ? h IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. ?y a723t3 2. 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 reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. (J 3. 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 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. 8123? If so, identify each account. Y4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? X10 5. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons give their full name and address. W&A File No. 166006571 XXX -XX-7896 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. n V 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. nD 8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). no 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer. V r Date: ?7 JD6 Amy F. Doy #87062 / Daniel F. Wolfson #20617 4io'1poCff!& ilip #86341 / David R. Galloway #87326 Chi #87852 / Sarah E. Ehasz #86469 o as, Jr. #201259 Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 XXX-XX-7896 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Tan ( (Name) Mera Derr Ist Fedml Credit Own betMnt 6 ?? of Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. JD6-,4 (SIGNATU ) ?°> C1 CO SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-00492 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS YOUNG JERRY And now ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:00 Hours, on the 12th day of March , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT YOUNG JERRY in the hands, possession, or control of the within named Garnishee MEMBERS 1ST FCU 1166 WALNUT BOTTOM RD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BETH WAGNER (ASST. MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 Sworn and Subscribed to before me this day of true and made So an;w ?? R. Thomas Kline Sheriff of Cumberland County 03/20/2008 ?/'??'?a$ I By - eputy 7heZiTf* A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 07-492 Civil Term ASSIGNEE OF OPTION CARD ASSIGNEE OF HOUSEHOLD BANK Plaintiff VS JERRY YOUNG Defendant(s) CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Members 1 st CU, discontinued, upon payment of your costs only Respectfully Submitted, Date: Amy F. Do le # 062 / - ilip C. Warhol c #863 /David R. Galloway #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 166006571 .4,q„ r u • R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Advance Costs: 150.00 Poundage 2.48 Sheriff s Costs: 126.38 Advertising 23.62 Law Library .50 Prothonotary 2.00 Refunded to Atty on 1/20/09 Milage 14.40 Surcharge 40.00 Levy 40.00 Certified Mail So Answers- Post Pone Sale oool Garnishee 9.00 ip ' Bad Check R. Thomas Kline, Sheriff Postage as f ° q T ` I C r Total 126.38 am, ?, c?.s By Claudia A. Brewbaker C rv n C? ? C-11 C) r xJ ' Z" j& r sv h'- J - Q J r N Ck. G7.77S' 8 691, ;2 j6 C)7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-492 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Assignee of OPTION CARD, Assignee of HOUSEHOLD BANK, Plaintiff (s) From JERRY YOUNG, 25 E Lisburn Rd., Apt 1, Mechanicsburg, PA 17055-5899 (1) You are directed to levy upon the property of the defendant (s)and to sell All personal property of any nature located within the household or immediate vicinity of the Defendant's address and all other personal property within the dominion and control of the Defendant wherever it is located shall be subject to the levy. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1" FCU, 1000 Bryn Mawr Rd., Carlisle, PA 17013 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, 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 $9,550.45 L.L. $.50 Interest from 4/03/07 at an interest rate of 6% per year - To be Determined Atty's Comm % Atty Paid $145.62 Plaintiff Paid Date: 3/11/08 Due Prothy $2.00 Other Costs Curtis R. Long, Pr n tary(Seal) By: Deputy REQUESTING PARTY: Name TONILYN M. CHIPPIE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011