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HomeMy WebLinkAbout07-2373IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. Q Z - pZ3 7? ?J l..tvc ?, ?/ly,? Plaintiff VS CIVIL ACTION - LAW REBBECCA E SNYDER Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), REBBECCA E SNYDER, for failure to answer the complaint. (X) Amount due TOTAL $2,885.35 ;ZS155*-P'1'us 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: Amy . Doyl 062 aniel 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 NOW, , 2002_, JUDGM IS ENTER AS ABOVE. Prot notary evil vision By: Deputy W&A File No. 147541501 o :OMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBER May. Dist. No, 09-3-05 MDJ Name. Hon. MARE MARTI?T -------- --- - - Address: 507 N YORK St MECHANICSBURG, PA Telephone: .(717 ) 766-4575 17055 ATTORNEY FOR PLAINTIFF : ANDREW C. SPEARS WOLPOFF & ABRAM 4660 TRINDLE RD THIRD FL CAMP HILL, PA 17011 10 ? NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRI_Y 'PALISADES COLLECTION LLC 4660 TRINDLE ROAD APT/STE 3 FL 01O--W6LP0FF -ABBAMSON _ LCAMP HILL, PA 17011 J vs. DEFENDANT: NAME ar,d AD>RE SS 'SNYDER, REBECCA E 29 E.000VER STREET MECHANICSBURG, PA 17055 L i Docket No.: CV-0000140-06 Date Filed: 4/26/06 THIS..V5.TO NOTIFY YOU THAT: _ Jtt tgTn-sn -JeDG r? -yir?-rlr` -°- - g Judgment was entered for. - - ? fNaTlle) [iA11j![?TTny f T C 0 Judgment was entered against: (Name) gmypiQ,Q? 1gzg1tC+c•a g in the amount of $ 2 - gg- i-q on: (Date of Judgment) 6/76 p6 Defendants are jointly and severally liable. ? (Date & Time) ? Damages will be assessed on: Amount of Judgment $ 2,764.85 a Judgment Costs $ 120.50 '`. Interest on Judgment $ .00 This case dismissed without prejudice. Attorney Fees $ .00 Total $ 2,885.35 ? Amount of Judgment Subje*t to Attachment/42 Pa.C.S. § 8127 $ Post Judgment Credits $ _ F-] Portion of Judgment for physical ost Judgment Costs $ damages arising out of residential lease $ Certified Judgment Total $ _ „- _ AF?4X PAFIT?F *FA&.TkIE-R#6*FT;T1> APREAL.+IFHIW3@ TEkTF#1? qF? - Jt1B6flAENT•8V t?1Q CE __M- - _ - - - OF APPEAL WITH THE PR6THONOTARY/CLERK OFTHE COURT OF:COMMON PLEAS, CIVIL DIVISI0O .-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 JUDGEMENT 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 A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge I certify that this is a true and correct c y of record of the proceedings containing the judgment. 01 ?oz a " Date ._Magisterial District,;.iudge My commission expires first Monday of January, 2012 . SEAL AOPC 315-05 DATE PRINTED: 6/26/06 10:31:40 AM C) ' ?, - o m5 r7. JAN 4 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. C* -.2373 d0iL Plaintiff VS CIVIL ACTION - LAW REBBECCA E SNYDER 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, Rebbecca E Snyder, above-named, is over 21 years of age; is last known to reside at 29 E Coover St Mechanicsburg, 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. Date: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Amy R. Wise, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 30, 2010 ? river, Fonnsy!varda Association of Notaries Amy F. Doyle #87 Da n ' F. Wolfson #2061 Philip C. Warholi 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 SWORN and SUBSCRIBED to before me this daYof , 20?? ?? my-m Notary Public W & A File No. 147541501 o rrr n t°s ? ? ? ? ^1 L3 i v rf y C) (T5 ` `c yT C r? `J ?L CA) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. Plaintiff VS REBBECCA E SNYDER Defendant(s) No. d? - 2.3Z3 CIVIL ACTION - LAW C?w????errL 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: Rebbecca E Snyder 29 E Coover St Mechanicsburg PA 17055 Date: Amy F. Doyle #870 Daniee olfson #20 Philip C. Warholic r6341 / 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 W&A File No. 147541501 r-? C7 -a c ? -v n r- Sri ' rn c ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. D'7 - ?cu 'r4 Plaintiff VS CIVIL ACTION - LAW REBBECCA E SNYDER Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: REBBECCA E SNYDER 29 E COOVER ST MECHANICSBURG, PA 17055 Yo are h reby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award (X) Judgment is in the amount of $2,885.35, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $1,870.74, attorney's fees in the amount of $0.00, interest in the amount of $894.11, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. ? By: 4 ca P thonota If you have any questions regarding this Notice, please contact the filing party. Date: Amy F. Doyle 062 / iel F. Wolfson #20617 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 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 W&A File No. 147541501 Telephone: (717) 303-6700 Counsel for Plaintiff a PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION,L.L.C. IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF AT &T CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. JUDGMENT NO. 07-2373 CIVIL TERM REBBECCA E SNYDER PRAECIPE FOR WRIT OF EXECUTION Defendant(s) (MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $2,885.35. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,REBBECCA E SNYDER located at 29 E COOVER ST, MECHANICSBURG, PA 17055, Defendant(s) (3) and against, COMMERCE BANK located at 20 NOBLE BLVD, CARLISLE, PA 17013, Gamishee(s); (4) and index this writ (a) against, REBBECCA E SNYDER , Defendant(s) and (b) against, COMMERCE BANK, 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) ***GARMH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of COMMERCE BANK located at 20 NOBLE BLVD, 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, docuiments of-title, securities, coupons and safe deposit boxes. Amount due $2,885.35 Interest from 04124/2007 To Be Determined At an interest rate of 6% per year Total $2,885.35 Plus costs & interest Date: 3 0 /817 Amy F. Doyle # 2 / Daniel 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. 147541501 XXX-XX-1458 'EA C ° rn -4 -TL r ?. ) ? I 2-1 W -_J j { c rn , ? ? 4 v w+ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-2373 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Assignee of AT&T, Plaintiff (s) From REBBECCA E SNYDER, 29 E. COOVER ST., MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMERCE BANK, 20 NOBLE BLVD., 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, SECURITIES, 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 $2,885.35 L.L. $.50 Interest from 4/24/07 at an interest rate of 6% per year Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Plaintiff Paid Date: 9/04/07 (Seal) REQUESTING PARTY: Other Costs CM "s R. Long, Prothonota By: ._l-. Jkt h-- 81?tu Deputy Name PHILIP C WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-02373 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION L L C VS SNYDER REBECCA E And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:35 Hours, on the 12th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT SNYDER REBBECCA E hands, possession, or control of the within named Garnishee COMMERCE BANK 20 NOBLE BLVD , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to NATHAN PORTER (CUSTOMER SERVICE REP) , personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to His . true and made Sheriff's Costs: So answers: Docketing .00 Service .00 .?i+?rt?riL Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .oooo 1, '1/111 /07 09/13/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D .? 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF AT &T Plaintiff VS REBBECCA E SNYDER Defendant(s) TO: COMMERCE BANK 20 NOBLE BLVD CARLISLE, PA 17013 No. 07-2373 CIVIL TERM CIVIL ACTION - LAW Aa5wets 4o INTERROGATORIES TO GARNISHEE 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. 147541501 XXX-XX-1458 INTERROGATORIES TO GARNISHEE DEFENDANT(S) - REBBECCA E SNYDER 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) maintains any of these jointly with any other person, or persons, give their name and address. No 1 A. 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. No 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. No 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. No 4. 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? No 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. No W&A File No. 147541501 XXX-XX-1458 t 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 propery 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. No 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. No 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. No Date: L - Amy F. Doyle 7062 / aniel F. Wolfson #20617 Philip C. Warholic #86 41 / 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 Commerce Bank 3801 Paxton Street Harrisburg, PA 17111 7 7-4 2-6134 Date W&A File No. 147541501 XXX-XX-1458 CJ T ' IM l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF AT &T Plaintiff VS REBBECCA E SNYDER Defendant(s) No. 07-2373 Civil Term CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Commerce Bank, discontinued, upon payment of yourcosts only. Date: i't "f Respectfully Submitted, Amy F. Doyle #7062 / t a Philip C. Warhblic #863 td #873 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #864469 Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000 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. 147541501 `AR Or W -•p t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N007-2373 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Assignee of AT&T, Plaintiff (s) From REBBECCA E SNYDER, 29 E. COOVER ST., MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMERCE BANK, 20 NOBLE BLVD., 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, SECURITIES, 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 $2,885.35 L.L. $.50 Interest from 4/24/07 at an interest rate of 6% per year Atty's Comm % Due Prothy $2.00 Atty Paid $54.25 Plaintiff Paid Date: 9/04/07 (Seal) REQUESTING PARTY: Other Costs C s R. Long, Prothonotar.Z By: C. Deputy Name PHILIP C WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 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 Poundage 1.69 Advertising Law Library .50 Prothonotary 2.00 Mileage 4.80 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee TOTAL 9.00 85.99 7"" 0S/04/a8 0 Advance Costs: 150.00 Sheriff's Costs 85.99 64.01 Refunded to Atty on 04/30/08 7 c.' So Answers, R. Thomas Kline, Sheriff By 4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, L_ Plaintiff No. 07-2373-Civil Term r- - r CIVIL ACTION REBBECCA E. SNYDER, - -" Defendant ; PRAECIPE FOR ENTRY OF APPEARANCE TO THE CLERK OF SAID COURT: Kindly enter my appearance on behalf of the Plaintiff in the above captioned matter. Date: August 6, 2013 By: an R. Mege,Fintiff' e Atty. I.D. #81 Attorney for P P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07-2373-Civil Term vs. : CIVIL ACTION REBBECCA E. SNYDER, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on, December 17, 2013, I served Plaintiff's Discovery In Aid Of Execution by mailing same, first class,post prepaid to: Rebbecca E. Snyder, 909 B Goodyear Rd., Gardners, PA 17324. By: Al. • ' . Mege, Esquire tty. I.D. #81288 Attorney for Plaintif P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 rn m(r- c' rrz -< co ' Mr, E 5'C ( ' " �: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07- 2373 -Civil Term VS. : CIVIL ACTION REBBECCA E. SNYDER, Defendant PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S ANSWERS TO INTERROGATORIES IN AID OF EXECUTION And now comes Plaintiff and submits the instant Motion to Compel, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of $2,885.35 plus costs was entered in Cumberland County on April 24, 2007. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on December 17, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. Counsel for Plaintiff has made a good faith effort to confer with Defendant, but Defendant has still failed to reply. 5. A copy of this Motion and proposed Order were mailed to Defendant, via first class mail on January 17, 2014. A certificate of Service is attached hereto as Exhibit "A ". 6. As of March 3, 2014, Plaintiff has not received answers to the Interrogatories. 7. Plaintiff requires an Order pursuant to Pa.R.C.P. 4019 (a) (1) (I), compelling the Defendants to answer the Interrogatories. 8. No Judge has ruled upon other issues in this matter. 9. Concurrence with the Pro Se Defendant has been sought and no response received. A copy of Plaintiff s January 17, 2014 letter is attached hereto as Exhibit "B". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and enter an Order directing the Defendant to answer Plaintiffs Interrogatories within twenty (20) days or risk sanctions, pay fees in the amount of $100.00, as well as such other and further relief as the Court may deem just and appropriate. an R. Mege, Esq. Attorney ID No. 8 88 Attorney for P1. tiffs P.O. Box 142 Bethlehem, PA 18016-1426 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07-2373-Civil Tenn VS. : CIVIL ACTION REBBECCA E. SNYDER, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on January 17, 2014, I served a true correct copy of Plaintiffs Motion to Compel Defendant's Answers to Interrogatories in Aid of Execution, proposed Order, and letter requesting concurrance by mailing same, first class, postage prepaid to: Rebbecca E. Snyder, 909 B Goodyear Rd., Gardners, PA 17324. By: . Mege, Esqu Atty. I.D. #81288 Attorney for Plai tiff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016-1426 LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ Todd A. Johns, Esq. Of Counsel Rebbecca E. Snyder 909 B Goodyear Rd. Gardners, PA 17324 RE: Dear Ms, Snyder: (610) 954-5393 (610) 954-5395 FAX AlanM_Esq@juno .com January 17, 2014 Our office intends to file a Motion to Compel Defendant's Answers to Interrogatories , a copy of which is enclosed. Please notify our office of your concurrance of same by February 3, 2014. If we do not hear from you by this time we will assume your concurrance. I appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments, please feel free to contact my office. ARM/11p Very truly yours, This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. PALISADES COLLECTION, LLC, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. REBBECCA E. SNYDER, DEFENDANT NO. 07-2373 CIVIL ORDER OF COURT AND NOW, this 12th day of March, 2014, upon consideration of Plaintiff's Motion to Compel, IT IS HEREBY ORDRED AND DIRECTED that Defendant shall provide full and complete answers to the interrogatories, without objection or motion for protective Order, within 20 days of the date of this Order or appropriate sanctions may be imposed upon Defendant following application to this Court. By the Court, s----Alan R. Mege, Esquire Attorney for Plaintiff Rebbecca E. Snyder Defendant bas C") • -,- rr c = COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07- 2373 -Civil Term VS. : CIVIL ACTION REBBECCA E. SNYDER, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on March 14, 2014, I served a true correct copy of this Court's March 12, 2014 Orderby mailing same, first class, postage prepaid to: Rebbecca E. Snyder, 881 Goodyear Rd., Gardners, PA 17324. By: . Mege, Esqui Atty. I.D. #81288 Attorney for Plai iff P.O. Box 1426 70 East Broad St. Bethlehem, PA 18016 -1426 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • PALISADES COLLECTION LLC, Plaintiff : No. 07-2373-Civil Term vs. • r.w-, : CIVIL ACTION ;,� REBBECCA E. SNYDER, - Defendant • 7 PLAINTIFF'S MOTION FOR SANCTIONS c=: And now comes Plaintiff and submits the instant Motion for Sanctions, and in support thereof avers as follows: 1. Judgment for Plaintiff and against Defendant in the sum of$2,885.35 plus costs was entered in Cumberland County on April 24, 2007. 2. Plaintiff served Interrogatories in Aid of Execution upon Defendant, via first class mail on December 17, 2013. 3. Pursuant to Pa.R.C.P. 4006 (a) (2), Defendant's responses to the Interrogatories were due within thirty days after they had been served, but none has been received as of the date of giving notice herein. 4. After notice, a Motion to Compel was filed and an Order entered on March 12, 2014, requiring Defendant, within twenty(20) days, to make full and complete answers to Interrogatories. A true and correct copy of the March 12, 2014 Order is attached as Exhibit"A". 5. As of April 14, 2014, Plaintiff has not received Defendant's answers to Interrogatories. 6. A copy of this Motion and proposed Order was sent to Defendant April 14, 2014. A Certificate of Service is attached hereto. 7. Counsel for Plaintiff sent correspondence to Defendant on April 14, 2014, seeking concurrence, and Defendant is unopposed. A true and correct copy of the correspondence is attached hereto as Exhibit "B". WHEREFORE, Plaintiff, requests that this Honorable Court grant its motion and Order that the Defendant shall pay a daily fine of$25.00 to the use of Plaintiff until Defendant complies with this Court's Order of March 12, 2014 and Defendant shall also pay$100.00 attorney's fees to Plaintiff within twenty (20) days of the date of this Order or appropriate sanctions will be imposed upon Defendant following application to this Court. Alan R. Mege, Esq. Attorney ID No. 81288 Attorney for Plaintiff PO Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393 -2- PALISADES COLLECTION, LLC, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. : REBBECCA E. SNYDER, • DEFENDANT : NO. 07-2373 CIVIL ORDER OF COURT AND NOW, this 12th day of March, 2014, upon consideration of Plaintiff's Motion to Compel, IT IS HEREBY ORDRED AND DIRECTED that Defendant shall provide full and i complete answers to the interrogatories, without objection or motion for protective Order, within 20 days of the date of this Order or appropriate sanctions may be imposed upon Defendant following application to this Court. By the Court, 1 1 I k M. L. Ebert, Jr_, 1 J. Alan R. Mege, Esquire Attorney for Plaintiff Rebbecca E. Snyder Defendant bas .--..-. c RECEIVED -0--r r =s cn — r;c_. MAR 1 4 2014 G y-r1 L r Law Offices of Alen McSe -- 1`J t 6-1%LADi -f-`t LAW OFFICES OF ALAN R. MEGE, ESQ. P.O. BOX 1426 70 EAST BROAD STREET BETHLEHEM, PA 18016-1426 Licensed in PA and NJ (610) 954-5393 Todd A. Johns, Esq. Of Counsel (610) 954-5395 FAX AlanM_Esq @juno.com April 14, 2014 Rebbecca Snyder 909B Goodyear Rd. Gardners, PA 17324 RE: Palisades Collection, LLC v. Snyder#07-2373-Civil Term Dear Ms. Snyder: You are in violation of the Court's Order of March 12, 2014, directing you to provide answers to the interrogatories. Because of this our office intends to file a Motion for Sanctions,a copy of which is enclosed. Please notify our office of your concurrance of same by April 28, 2014. If we do not hear from you by this time we will assume your concurrance. I appreciate your assistance in bringing this matter to an amicable conclusion. Should you have any questions or comments,please feel free to contact my office. Very truly yours, Alan R. Mege ARM/11p FILE COPY This message is from a debt collector, this is an attempt to collect a debt, and any information obtained will be used for that purpose. r PALISADES COLLECTION, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PEND§YLVANIA c -0Z V. niz.o REBBECCA E. SNYDER .`"<i Defendant : NO. 07-2373 CIVIL <ED c -a A C-171 ORDER OF COURT cp AND NOW, this 15th day of May, 2014, upon consideration of the Plaintiff's CD Motion for Sanctions and it appearing that the Defendant has failed to comply with this Court's Order of March 12, 2014; IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall issue upon the Defendant to show cause why she should not be held in contempt; 2. The Rule is returnable on Thursday, June 26, 2014, at 10:30 a.m. in Courtroom No. 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania, at which time a hearing shall be held on the matter. IT IS FURTHER ORDERED AND DIRECTED that should the Defendant fail to appear for the scheduled hearing, the Rule shall be made absolute and a warrant shall issue for her arrest. The Sheriff is directed to serve this Order upon the Defendant. By the Court, Alan R. Mege, Esquire, 70 E. Broad Street, Bethlehem, PA 18018 /Rebbecca Snyder, 909B Goodyear Road, Gardners, PA 17324 bas S sfish etsiotegv PL/1 s.//Is/1y PALISADES COLLECTION, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA E. SNYDER, Defendant CIVIL ACTION NO. 07 -2373 CIVIL TERM..3 fT1G7 NOTICE TO PLEAD TO: Alan R. Mege, Esquire 3> <= P.O. Box 1426 Bethlehem, PA 18016 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED ANSWER TO COMPLAINT WITH NEW MATTER WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. By: Date: May 29, 2014 IRWIN & McKNIGHT, P.C. Marcus cKni ht, II Esquire 60 West ' , mfret Street Carlisle, Penn ylvania 17013 - 222 (717) 249 -235 Supreme Court ID. No. 25476 Attorney for Defendant PALISADES COLLECTION, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. REBECCA E. SNYDER, Defendant CIVIL ACTION NO. 07-2373 CIVIL TERM ANSWER TO PLAINTIFF'S MOTION FOR SANCTIONS WITH NEW MATTER AND NOW, this 29th day of May, 2014, comes the Defendant, Rebecca E. Snyder, by her attorneys Irwin & McKnight, PC and make the following Answer to Plaintiff's Motion for New Matter. 1. A judgment was entered against the defendant on April 24, 2007 in the amount of $2885.35 plus costs. At the time of the judgment the defendant. Rebecca E. Snyder was married to her husband. All assets were jointly owned and have remanded so to this date. 2. The averment of fact contained in paragraph two (2) of the Motion are admitted in part and denied in part. It is admitted that counsel for the plaintiff filed an Affidavit of Service. It is denied that the defendant ever received the interrogatories. 3. The averment of fact contained in paragraph three (3) are specifically denied. On the contrary, the defendant cannot answer interrogatories she has never received. 2 4. The averment of fact contained in paragraph four (4) are admitted. 5. The averment of fact contained in paragraph five (5) are admitted. 6. The averment of fact contained in paragraph six (6) are admitted. 7. The averment of fact contained in paragraph seven (7) are admitted. WHEREFORE, the Motion for Sanctions should be dismissed with prejudice. NEW MATTER AND NOW, comes the Defendant, Rebecca E. Snyder, by her attorneys Irwin & McKnight, PC and make the following New Matter. 8. The averment of fact contained in paragraphs one (1) through seven (7) of Defendant's Answer are incorporated by reference and made a part of this New Matter. 3 9. The Defendant has no assets which the defendant is able to sell or extract payment, they are all jointly owned with husband. 10. The lien of the judgment expired after five (5) years and have not been reveived by the Plaintiff. The need to serve and answer interrogatories is moot since the lien has not been reveived by the Plaintiff. WHEREFORE, the Motion for Sanctions should be dismissed with prejudice with reasonable attorney fees paid to Defendant. Date: May 29, 2014 Respectfully submitted IRWIN & McKNIGH P.C. : Marcus McKnig t, III, Esqu West Pomfret Street Carlisle, (717) 249-2353 Supreme Court I.D. No. 25476 4 VERIFICATION The foregoing document is based upon information, which has been gathered by my counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. By: Date: REBECCA E. SNYDER PALISADES COLLECTION, INC., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION REBECCA E. SNYDER, . Defendant • NO. 07-2373 CIVIL TERM CERTIFICATE OF SERVICE I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached document was served upon the following by depositing a true and correct copy of the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania, on the date referenced below and addressed as follows: Alan R. Mege, Esquire P.O. Box 1426 Bethlehem, PA 18016 IRWIN & McKNI T, P.C. By: Ma cus A. McKnight, II, Esquire 60 est Pomfret Street Carlisle, PA 17013 ��1� 249 -2353 Suprem , s urt I.D. No. 25476 Date: May 29, 2014 5 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07 -2373 -Civil Term' vs. : CIVIL ACTION REBBECCA E. SNYDER, Defendant MOTION FOR CONTINUANCE Palisades Collection, LLC. by and through its counsel, Alan R. Mege, Esquire, hereby moves this Honorable Court for a continuance and in support thereof states as follows: 1. A hearing is currently scheduled with regard to Plaintiffs Motion for Sanctions in the above -captioned matter on June 26, 2014 at 10:30 am. A copy of the Cumberland County Order is attached as Exhibit "A". 2. A continuance is requested to allow time for Discovery Answers to be provided by Counsel 3. Notice of this Motion and proposed Order were mailed to Defendant, via first class mail on May 19, 2014. A certificate of Service is attached hereto. WHEREFORE, Plaintiff and Counsel for Defendant, requests that this Honorable Court grant their motion and enter an Order continuing the June 26, 2014 hearing to a later date and time. By: an R. Mege, Esqu Atty. I.D. #81288 Attorney for P1 ntiff PALISADES COLLECTION, LLC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA C? ry G7 V. -n 3 ` M CO . _ rii z Xin-< _^-. co r" — r"_, ..., ..< D C.►1 C 7 2 o—r, i>" .. C=2 AND NOW, this 15th day of May, 2014, upon consideration of the Plaintiff's 2 REBBECCA E. SNYDER Defendant : NO. 07-2373 CIVIL ORDER OF COURT Motion for Sanctions and it appearing that the Defendant has failed to comply with this Court's Order of March 12, 2014; IT IS HEREBY ORDERED AND DIRECTED that: 1. A Rule shall issue upon the Defendant to show cause why she should not be held in contempt;' 2. The Rule is returnable on Thursday, June 26, 2014, at 10:30 a.m. in Courtroom No, 6 of the Cumberland County Courthouse, Carlisle, Pennsylvania, at which time a hearing shall be held on the matter. IT IS FURTHER ORDERED AND DIRECTED that should the Defendant fail to appear for the scheduled hearing, the Rule shall be made absolute and a warrant shall issue for her arrest. The Sheriff is directed to serve this Order upon the Defendant. By the Court, Alan R. Mege, Esquire, 70 E. Broad Street, Bethlehem, PA 18018 Rebbecca Snyder, 909B Goodyear Road, Gardners, PA 17324 bas eYkA01:-Pti4" RECEIVED MAY 1 9 2014 Law Offices of Alan Mege COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07 -2373 -Civil Term vs. : CIVIL ACTION REBBECCA E. SNYDER, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on June 4, 2014, I served upon Defendant, Plaintiff's Motion for Continuance and proposed Order by mailing same, regular mail, postage prepaid to: Rebbecca E. Snyder, c/o Marcus A. McKight, III, Esq., 60 W. Pomfret St., Carlisle, Pa 17013 By. elan R. Mege, Esquir Atty. I.D. #81288 Attorney for Pla' tiff P.O. Box 1426 Bethlehem, PA 18016 (610) 954-5393 4 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff No. 07 -2373 -Civil Term VS. REBBECCA E. SNYDER, Defendant AND NOW, this J 1 day of : CIVIL ACTION ORDER r` s CD c,n CD rn_T, nt_ , 201, it is hereby ordered and decreed that the Plaintiff s Motion for Continuance is Granted and the hearing originally scheduled for O,2014at 3.tO June 26, 2014 at 10:30 a.m. shall be continued until m . Courtroom # of the Cumberland County Courthouse, Carlisle, PA 17013- 3387. BY THE COURT: Distribution: Alan R. Mege, Esquire, 70 E. Broad St., PO Box 1426, Bethlehem, PA 18016-1426 Rebbecca Snyder, c/o Marcus A. McKnight, III, Esq. 60 W. Pomfret St., Carlisle, PA 17013 CO?1e_S /' . 1.1£x. iii/iy ,\\)cii- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV IN. rnC° 1'` Fri ma r- �yy co C7 :Z : CIVIL ACTION z' CJ REBBECCA E. SNYDER, Defendant PALISADES COLLECTION LLC, Plaintiff : No. 07 -2373 -Civil Term VS. PRAECIPE TO WITHDRAW PLAINTIFF'S MOTION FOR SANCTIONS TO THE CLERK OF SAID COURT: Please withdraw the Motion for Sanctions filed in the above -captioned matter. Date: August 14, 2014 Alan R. Mege, Esq. Attorney ID No. 288 Attorney for P. intiff P.O. Box 14' 6 Bethlehem, PA 18016 (610) 954-5393 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC, Plaintiff : No. 07 -2373 -Civil Term vs. : CIVIL ACTION REBBECCA E. SNYDER, Defendant CERTIFICATE OF SERVICE I, Alan R. Mege, Esquire, hereby certify that on August 14, 2014, I served upon Defendant, a true and correct copy of Plaintiff's Praecipe to Withdraw Plaintiff's Motion for Sanctions by mailing same, first class, postage prepaid to: Rebbecca E. Snyder, c/o Marcus A. McKight, III, Esq., 60 W. Pomfret St., Carlisle, Pa 17013. By: A1arrk. Mege, Esquire Atty. I.D. #81288 Attorney for Plaint' 'f P.O. Box 1426 Bethlehem, PA 18016-1426 (610) 954-5393