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Home My WebLink About03-5659IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION c/o WOLFSON & ASSOCIATES, P.C. 267 EAST MARKET STREET YORK, PA 17403 VS. DONNA M PASSARO AND STEPHEN PASSARO 101B WYNCOTE CT MECHANICSBURG, PA 17055 File No. t~X,.'~ -- ,~/_.~ Civil Action - Law PRAECIPE FOR SUMMONS TO THE PROTHONOTARY/CLERK: Issue summons in Law in the above case. XX Date: Writ of Summons shall be issued and forwarded to Defendant. Amy F. Wolfson, Esquire WOLFSON & ASSOCIATES, P.C. 267 East Market Street York, PA 17403 (717) 846-1252 Supreme Court ID Number 87062 SUMMONS IN CIVIL ACTION TO: DONNA M & STEPHEN PASSARO 101B WYNCOTE CT MECHANICSBURG, PA 17055 (Defendant Name and Address) YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAINTIFF(S) HAS/HAVE COMMENCED AN ACTION IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES : CORPORATION, A MARYLAND : CORPORATION ASSIGNEE OF : FORWARD PROPERTIES, INC., : ASSIGNEE OF BANKFIRST : CORPORATION, Plaintiff VS. : CIVIL ACTION-LAW DONNA M. PASSARO AND STEPHEN PASSARO, : Defendant : STIPULATION OF JUDGMENT AND NOW, this :Z/~'day of.~,~,~,~,~,~,~,~,~ ~= ,2~ ~,, come the par~ies to this action, by and through their respective counsel and/or individually, and hereby stipulate and agree as follows: 1. On July 24, 2003, Plaintiff filed a District Justice Complaint against Defendant alleging monies due and owing on Defendant's account with Plaintiff. 2. The parties hereto, by and through their counsel or individually, agree to the withdrawal of the District Justice action and the entry of Judgment in the amount of One Thousand Seven Hundred Ten and 68/100 ($1,710.68) Dollars. 3. The Defendant hereby agrees to make monthly payments on the Judgment in the amount of One Hundred Sixty-Seven 00/1 O0 ($167.00) Dollars, until this matter is paid in full. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, Plaintiff VS. DONNA M PASSARO AND STEPHEN PASSARO, Defendant : CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R. C. P. 2:36 I, hereby certify that the precise residence of Plaintiff is: PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION c/o WOLFSON 8z ASSOCIATES, P.C. 267 EAST MARKET STREET YORK, PA 174.03 and certify that the last known address of the within Defendant is: DONNA M ~z STEPHEN PASSARO 101B WYNCOTE CT MECHANICSBURG, PA 17055 WOLFSOI4 ~ ASSOCIATES, P.C. 267 East Market Street York, PA 17403 (717) 846-1252 ID No. 87062 Attorney for Plaintiff 4. The parties agree that the first payment on the Judgment is due on or before October 15, 2003 and all subsequent payments are due on or before the 15th day of each month, until this matter is paid in full. 5. Counsel for Plaintiff hereby agrees to take no post-]udgment action as long as the Defendant continues to make regular and timely monthly payments as indicated herein. 6. Counsel for the Plaintiff hereby certifies that they are authorized to enter into this instant Stipulation on behalf of their client. NOW, THEREFORE, the undersigned parties hereby request a Judgment be entered in favor of Plaintiff and against Defendant consistent with the terms of this Stipulation. WOLFSON e~ ASSOCIATES, P.C. 267 East Market Street York, PA 17403 (717) 846-1252 Attorney for Plaintiff Donna M. Passaro (Defendant) Stephen Passaro (Defendant) IN THE COURT OF COI~Ii~ION PLEAS OF CUI~'IBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, Plaintiff VS. DONNA M PASSARO AND STEPHEN PASSARO, Defendant : CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R, C. P. 236 I, hereby certify that the precise residence of Plaintiff is: PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION c/o WOLFSON e~ ASSOCIATES, P.C. 267 EAST MARKET STREET YORK, PA 17403 and certify that the last known address of the within Defendant is: DONNA M ~ STEPHEN PASSARO 1018 WYNCOTE CT MECHANICSBURG, PA 17055 267 East I~larket Street York, PA 17403 (717) 846-1252 ID No. 87062 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, Plaintiff VS. DONNA M PASSARO AND STEPHEN PASSARO, Defendant No. CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF YORK : I, Amy F. Wolfson, Esquire, 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, DONNA M PASSARO, above named, is over 21 years of age; is last know to reside at 101 B WYNCOTE CT MECHANICSBURG, PA 17055, CUMBERLAND County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendments. Attorney for the Plainfffff Attorney ID#87062 Wolfson e~ Associates, P.C. 267 East Market Street York, PA 17403 SWORN and SUBSCRIB~Ep to b~ore r~e/this ,~,_~ ~ ~OMMONWEALTH OF pENNSYLVANIA J Notarial Seal I Stacie M. Stem, Notaq' Public J City of York York County ~ My Commission Exp r~s Dec. 5, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORPORATION, A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, Plaintiff DONNA M PASSARO AND STEPHEN PASSARO, Defendant No. CIVIL ACTION- LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : : COUNTY OF YORK : I, Amy F. Wolfson, Esquire, being duly sworn according to law, depose and say that [ am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, STEPHEN PASSARO, above named, is over 21 years of age; is last know to reside at 10lB WYNCOTE CT MECHANICSBURG, PA 17055, CUMBERLAND County, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its Amendn:lents. Amy 1~. Wolf)fi)n, Esquire J Attorney fod the Plaintiff Attorney ID#87062 Wolfson 8~ Associates, P.C. 267 East Market Street York, PA 17403 SWORN and SUBSCRIBED to bef,~e~ n~e)fh!s c~/~da~ Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Staci¢ M. Stem, Notary Publie City of York, York County My Commission Expires Dec. 5, 2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PLATINUM FINANCIAL SERVICES CORP., A MARYLAND CORPORATION ASSIGNEE OF FORWARD PROPERTIES, INC., ASSIGNEE OF BANKFIRST CORPORATION, INC. P.O. BOX 10247 ROCKVILLE, MD 20849-0247 Plaintiff VS. DONNA M PASSARO STEVEN PASSARO PO BOX 13 MECHANICSBURG PA 17055-0013 Nc. 0oo' 5- OSU S Defendant (s) : PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, SATISFIED AND DISCONTINUED. Respectfully submitted, By: Daniel F. Wolfson #20617 Bruce H. Cherkls #18837 Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff CC: PAPR4/PA176A W&A PILE NO. 104023893