HomeMy WebLinkAbout07-5701IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON No. 07- 5`701 olvilTerm
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
CIVIL ACTION - LAW
vs.
STACY WATSON
Defendant(s)
PRAECIPE FOR ENTRY OF EXEMPLIFIED JUDGMENT
To the Prothonotary:
Please enter the attached Exemplified record as a civil judgment.
Respectfully Submitted,
Date: 3 c?
Amy F. Doyle #1062 / Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / 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. 167231210
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON No.
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
CIVIL ACTION - LAW
vs.
STACY WATSON
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), Stacy Watson , pursuant to the attached
Exemplified Judgment Record.
( X) Amount due $1,951.98
TOTAL $1,951.98, 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:
Amy F. Doyle 7062 / Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / 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, , 20Q7-, JUDGMENT IS ENTERED AS ABOVE.
S ?•
'Plothonotary/Clerk, Civil Idvision
By: UOU au
Deputy
W&A FILE NO. 167231210
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
VS
STACY WATSON
Defendant(s)
No.
CIVIL ACTION - LAW
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, Stacy
Watson, above-named, is over 21 years of age; is last known to reside at 321 S 3Rd St Lebanon, County of Lebanon,
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.
3 C? f /,4/
41 ?
Date:
Amy F. Doyle #87062 / 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 / Ronald S. Canter #94000
Ronald M. Abramson #94266
Wolpoff & Abramson, L.L.P.
Attorneys in the Practice of Debt Collection
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Brandi M. Moody, Notary Public
Hampden T%v-, Cumberland County
My Corrrr"on Expires Nov. 30, 2010
Member, Pennsylvania Association of Notaries
4660 Trindle Road, Suite 300
Camp Hill, PA 17011
Telephone: (717) 303-6700
Counsel for Plaintiff
SWORN and SUBSCRIBED to before me this day of S 20-0L.
1%. 1
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4 Id,
Notary Public
W & A File No. 167231210
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON
ASSIGNEE OF VERIZON NORTH INC No.
Plaintiff
VS
CIVIL ACTION - LAW
STACY WATSON
Defendant(s)
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:
Stacy Watson
321 S 3Rd St
Lebanon PA 17042
Date:
1 Amy F. Doyle #87062 Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / 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. 167231210
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON NO.
ASSIGNEE OF VERIZON NORTH INC
Plaintiff CIVIL ACTION - LAW
vs.
STACY WATSON
Defendant(s)
AFFIDAVIT OF FOREIGN JUDGMENTS
Commonwealth of Pennsylvania
County of CUMBERLAND
ss.
AND NOW, TO WIT, this day of , 20 , comes the undersigned
who being duly sworn according to law, deposes and says that they are the Attorney for the Plaintiff in
the above-captioned action; that the judgment is valid, enforceable and unsatisfied.
u__4'k1
(/Zv/
Amy F. Doyle #87062 Daniel F. Wolfson #20617
Philip C. Warholic #8A41 / David R. Galloway #87326
Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / 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 day
of , 20_.
Notary Public
W&A File No. 167231210
IN THE COURT OF COMMON PLEAS OF LEBANON COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
No. 2007-00811
VS
STACY WATSON
Defendant(s)
PRAECIPE TO REQUEST EXEMPLIFIED JUDGMENT
To the Prothonotary:
Please provide an Exemplified Judgment for this matter.
Respectfully Submitted,
? f
Date:
r ? Amy F. Doyle #8706f/ Daniel F. Wolfson #20617
Philip C. Warholic #6341 / 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. 167231210
v,? ?J
Date: 7/27/07 COURT OF COMMON PLEAS OF LEBANON COUNTY Time: 12:08:03
PALISADES COLLECTION ASSIGNEE-VERIZON
Action No. 2007-00811
vs. CIVIL DIVISION
STACY WATSON
CERTIFICATION
COMMONWEALTH OF PENNSYLVANIA:
:ss
COUNTY OF LEBANON
I, Lisa M. Arnold, Prothonotary of the Court of Common Pleas
of Lebanon County, Pennsylvania, do hereby certify that the above and
foregoing pages contain a true copy and correct transcript of the
docket entries, which form the whole record in the foregoing suit, and
that Judgment has been entered and certified in favor of the Plaintiff
and against the Defendant(s) in the sum of $1,951.98
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the
Seal of the said Court at Lebanon, Pennsylvania, this Twenty-seventh
day of July, 2007.
v?
Prothonotary
Date: 7/27/07 COURT OF COMMON PLEAS OF LEBANON COUNTY Time: 12:08:03
PALISADES COLLECTION ASSIGNEE-VERIZON
Action No. 2007-00811
vs. CIVIL DIVISION
STACY WATSON Docket Entries 1 through 2
5/01/07 JUDGMENT FROM THE DOCKET OF A DISTRICT JUSTICE IN THE AMOUNT OF
1076/0311 $1,951.98, FILED. DEFENDANT NOTIFIED. AFF. OF NON-MILITARY SERVICE,
JUDGMENT ENTERED. TONILYN M. CHIPPIE
7/20/07 PRAECIPE FOR AN EXEMPLIFIED RECORD OF JUDGMENT, FILED.
1088/0054
PHILIP C. WARHOLIC
Date: 7/27/07 COURT OF COMMON PLEAS OF LEBANON COUNTY Time:12:08:03
PALISADES COLLECTION ASSIGNEE-VERIZON
Action No. 2007-00811
vs. CIVIL DIVISION
STACY WATSON
COMPLETE CAPTION
Plaintiff(s) Attorney
PALISADES COLLECTION ASSIGNEE-VERIZON TONILYN M. CHIPPIE
4660 TRINDLE RD, STE. 300
CAMP HILL, PA. 17011
Defendant(s)
STACY WATSON
321 S. 3RD. ST.
LEBANON, PA. 17042
Date: 7/27/07 COURT OF COMMON PLEAS OF LEBANON COUNTY Time: 12:08:03
PALISADES COLLECTION ASSIGNEE-VERIZON
Action No. 2007-00811
VS. CIVIL DIVISION
STACY WATSON
INDEX ENTRIES
Party Indexed as .. : WATSON, STACY
First Opposing Party: PALISADES COLLECTION
Comment . . . . . . : DJ JUDG
Filed on: 5/01/07 Microfilmed at: 1076/0311 Judgment Amount: $1,951.98
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF VERIZON No.
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
CIVIL ACTION - LAW
vs.
STACY WATSON
Defendant(s)
NOTICE OF JUDGMENT
( x ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of
$1,951.98, plus interest, on Zgpf 20I_•
(x) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached.
By: 5
Oa
If you have any questions regarding this Notice, please contact the filing party.
p &Vv
Date
: L-A
Amy F. Doyle #87062 Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / 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: Stacy Watson
321 S 3Rd St
Lebanon PA 17042
W&A File No. 167231210
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 VERIZON CUMBERLAND COUNTY, PENNSYLVANIA
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
VS.
STACY WATSON JUDGMENT NO. 07-5701 CIVIL TEAM
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 $1,951.98.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against,STACY WATSON located at 321 S 3RD ST, LEBANON, PA 17042, Defendant(s)
(3) and against, ORRSTOWN BANK located at 22 S HANOVER ST, CARLISLE, PA 17013-3306, Garnishee(s);
(4) and index this writ
(a) against, STACY WATSON , Defendant(s) and
(b) against, ORRSTOWN 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) ***GARNISH ONLY***
You are directed to attach the property of the Defendant(s) not levied upon in the possession of
ORRSTOWN BANK located at 22 S HANOVER ST, CARLISLE, PA 17013-3306, 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 $1,951.98
Interest from 09/28/2007 To Be Determined
At an interest rate of 6% per year
Total $1,951.98 Plus costs & interest
Date: d? b z4A -
aniel F. Wolfson #20617
Philip C. Warholic #86341 David R. Galloway #87326
om yn M. Chippie #87852 / 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. 167231210
XXX-XX-b739
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-5701 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION, L.L.C., Assignee of
VERIZON, assignee of VERIZON NORTH INC., Plaintiff (s)
From STACY WATSON, 321 S. 3`d Street, Lebanon, PA 17042
(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:
ORRSTOWN BANK, 22 S. Hanover Street, CArlisle, PA a17013-3306
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 $1,951.98
L.L. $.50
Interest from 9/28/07 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 3/07/09
(Seal)
REQUESTING PARTY:
Name PHILIP C. WARHOLIC, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
Due Prothy $2.00
Other Costs
LRP. Crm
dis . LBy:
Deputy
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: 2007-05701 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
WATSON STACY
And now WILLIAM CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:23 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
WATSON STACY
hands, possession, or control of the within named Garnishee
ORRSTOWN BANK 22 S HANOVER ST
. in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JACKIE JUMPER (OFFICE MANAGER)
personally three copies of interogatories together with 3 true
and attested copies o f the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: So answe
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
? 3IIPr0? ?i..
00
03/14/2008
Sworn and Subscribed
fore me this
b to
day of By
e Deputy Sheriff
A.D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C. No. 07-5701 CIVIL TEAM
ASSIGNEE OF VERIZON
ASSIGNEE OF VERIZON NORTH INC
Plaintiff
VS
STACY WATSON
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, ORRSTOWN BANK, discontinued, upon payment of your
costs only.
Respectfully Submitted,
Date: 1
Amy F. Doyle #8706 /JQRj? . arholic #8
David R. Galloway #873 /Sarah hasz #8 469 /
Robert N. Polas, Jr. #201259
Mann Bracken LLC
The Successor by Merger to Wolpoff & Abramson, L.L.P.
and Eskanos & Adler, P.C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: (717) 303-6700
Counsel for Plaintiff
File No. 167231210
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
( Writ is returned ABANDONED, no action taken in six months.
C?D
heriff's Costs:
Docketing 18.00 Advance Costs: '150.00
WPoundage 1.69 Sheriff's Costs: 85.99
- Advertising 64.01
Law Library .50
Prothonotary 2.00 Refunded to Atty on 1/20/09
Milage 4.80
Surcharge 30.00
Levy 20.00
Certified Mail So Answe
Post Pone Sale `?
Garnishee 9.00 r
Bad Check R. Thomas Kline, Sheriff
Postage ? Oautjj
85.99 v' ?-- -' ..
Total
By Claudia A. Brewbaker
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-5701 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION, L.L.C., Assignee of
VERIZON, assignee of VERIZON NORTH INC., Plaintiff (s)
From STACY WATSON, 321 S. 3rd Street, Lebanon, PA 17042
(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:
ORRSTOWN BANK, 22 S. Hanover Street, CArlisle, PA a17013-3306
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 $1,951.98
L.L. $.50
Interest from 9/28/07 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 3/07/09
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs
"F NOOMMd "4
. Long, Prothonotary By:
s R?Le6n'- F, NLt' ow.
Deputy
Name PHILIP C. WARHOLIC, 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. 86341