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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 0, f n 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 _ --,5 " l7 th- C C- _-J -71 00 ? ? Do i ` J U i_ 3 0 '001 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 -t- b a n ti -GL O V F? O o N a OD 3a' 0 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 7p -6? 00 SZi T 3 sY _ , _ rri J S °Q =c:; ` CA) 3 44 ? o ` -< 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 n C 8 E .E d L- M BOOT ?J3WHS 3N1t?0 ? iOV ,2, N O 0 ..v UN C17 0 'TI I? _.,., rn _{ Z7 -7 -7 z/ c Q 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