HomeMy WebLinkAbout07-7195IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTIOML.L.C.
ASSIGNEE OF AT &T
Plaintiff No. 07 -- ?l ?s?, `(, ??'1
VS CIVIL ACTION - LAW
JOSEPH STANTON
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), JOSEPH STANTON , for want of pursuant to the
District Justice Transcript.
(X) Amount due $1,878.71
TOTAL $1,878.71, 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.
( ) 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 #87062 / Daniel F. Wolfson #20617
Philip C 86341 / David R. Galloway #87326
onil n M_. * ' 852 / Sarah E. Ehasz #86469
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
NOW, , 20AQL, JUDG IS E AS ABO
0 onotary/Clerk, Civil Divisi
By:
Deputy
W&A File No. 154988831
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-COMMONWEALTH OF PENNSYLVANIA NOTICE OF JUDGMENT/TRANSCRIPT
COUNTY DF: >4yMBNRiAND CIVIL CASE
Mag. Dist No.:
09-3-04
MDJ Name: Hon.
THOMAS A. PLACBY.
Address: 104.S SPORTINQ RILL ;RD
MECHANICSBURG, PA
Telephone (7 17 ) 761--8230 17050
PLAINTIFF: NAME and ADDRESS
FPALISADES COLLECTION ASON AT&T
4669 TRI39DLE ' ROAD
C/O VOLPOFF'& ABRAMSON
LCAMP HILL, PA 17,011 J
VS.
DEFENDANT: NAME and ADDRESS'
rSTM",QN, JOSEPH
419 $AST:000VER ST ,A
MECHANICSRURG,;PA 17055
PALISADES COLLECTION ASGN AT&T L J
4660 TRINDLE ROAD Docket No.: CV-0000345-06
C/O VOLPOFF & ABRAMSON Date Filed: 6/15/06
CAMP HILL, PA 17011
THIS IS TO NOTIFY YOU THAT:
D$FAIILT J?DGMENT.PLTF 8/23/07
4adgrnent: t g
out?d -
(Da f amnt) e
E .
® Judgment was entered for:- (Name) PALISADES COLLECTION ASGN AT&T
Judgment was entered against: ((Name) STANTON, JOSEPH
in the amount of $ 1, 878.7
Defendants are jointly and severally liable.
ry
Damages will be assessed on Date & Time
0
This case dismissed without 'orejudice.
Amol nt of Judgment Subject to Attachment/42 PaC.S. § 8127
Portic: n of Judgment for physical damages arising out of
resid-ntial lease $
K
r
ANY PART ' HAS THE RIGHT TO APPEAL, WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING -A NOTICE
OF APPEAL 1 ITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS; CIVIL. DIVISION. YOU '
MUST iNCLUI)E A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
E
EXCEPT A': OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
I, _.,JUQGEA?LENT LDER EI.ECTS,?TO.ENTER THE JUDGMENT IN THE COURT Of COMMON PLEAS, ALL FURTHER PROCESS MUST
"COM 'F`RCfil? ' COUR OF`G`OhAAiIdN PLI 7Ik5 1ND'NO FU TH 'pRO?" Ss'MAIf 0l" ?0 B1fi NtAiIS"?Lf?t1AL I)if3T 01 :t Fk#DIM ?
UNLESS THE JUDGMENT IS ENTERED IN'THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY,FILE
A REQUEST OR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OIL `OTHERWISE COMPLIES WITH THE JUDGMENT.
,. 7
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O. Date , Magisterial District Judge
certify 0 at this is a tr r ect copy "oft ttcord of the p ings containinithe judgment: .
67 Date Magisterial Djst(ict.Judge
My commission expires first Monday of January, 2010 SEAL
AOPC 315-06
DATE PRINTED: 8/23/07 9:52:00 AM
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T No.
Plaintiff
VS CIVIL ACTION - LAW
JOSEPH STANTON
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, Joseph
Stanton, above-named, is over 21 years of age; is last known to reside at 419 E Coover St Mechanicsburg, County of
Cumberland, Pennsylvania; is not in the military service of the United States or its Allies, &otherwise within the
provisions of the Servicemembers Civil Relief Act and its Amendments.
Date: - D '--
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. Warh 41 / David R. Galloway #87326
-- ni yn . Chippie #8 ah E. Ehasz 086469
o rt . o as, r. #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.
COMMONWEALTH OF PENNSYLVANiA'elephone: (717) 303-6700
Notadai Sew ounsel for Plaintiff
Brands M. Moody, Notary PUbiic
Harrqpden Twp., Cwibedano GoL^
My COrn T*won E)Ores Nov. 30, 2010
Member, Pennsylvania Association of Notaries
SWORN and SUBSCRIBED to before me this o`)S+ day of ?V"kYr , 20-a.
&CM4A., 0, 4'
Notary Public.
W & A File No. 154988831
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T No.
Plaintiff
VS
CIVIL ACTION - LAW
JOSEPH STANTON
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:
Joseph Stanton
419 E Coover St
Mechanicsburg PA 17055
Date:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
_ Phj r A ? / David R. Galloway #87326
. Chi arah E. Ehasz #86469
e . 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. 15498'8831
77>
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T No.
Plaintiff
VS
CIVIL ACTION - LAW
JOSEPH STANTON
Defendant(s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: JOSEPH STANTON
419 E COOVER ST
MECHANICSBURG, PA 17055
Y are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on
O67 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 $1,878.71, plus costs.
(X) District Justice transcript of judgment in civil action in the amount of $1,099.11, attorney's fees in the
amount of $219.82, interest in the amount of $454.28, 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:
P thonotary
If you have any questions regarding this Notice, please contact the filing party.
Date:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
__ Philip (:_ Warhol' #86341 / David R. Galloway #87326
o ilyn M. Chi ie 852 / Sarah E. Ehasz #864,69
olas, 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. 154988831
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T
Plaintiff
VS.
JOSEPH STANTON
Defendant(s)
IN THE COURT OF-COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 07-7195-CIVIL
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 $1,878.71.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against,JOSEPH STANTON located at 419 E COOVER ST, MECHANICSBURG, PA 17055, Defendant(s)
(3) and against, SOVEREIGN BANK located at 17 W HIGH ST, CARLISLE, PA, Garnishee(s);
(4) and index this writ
(a) against, JOSEPH STANTON , Defendant(s) and
(b) against, SOVEREIGN 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
SOVEREIGN BANK located at 17 W HIGH ST, CARLISLE, PA , 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 $1,878.71
Interest from 11/2912007 To Be Determined
At an interest rate of 6% per year
Total $1,878.71 Plus costs & interest
C
Date: 161,10t
Amy F. Doyle #8 *2 / Daniel F. Wolfson #20617
Philip C. Warholi #86341 / David R. Galloway #87326
Tonilyn 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. 154988831 XXX-XX-6860
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7195 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 AT &
T, Plaintiff (s)
From JOSEPH STANTON, 419 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:
SOVEREIGN BANK, 17 W High Street, 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 $1,878.71
L.L. $.50
Interest from 11/29/07 at an interest rate of 6% per year -- To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 1/22/08
(Seal)
Due Prothy $2.00
Other Costs
(It V-V"-)U4
Curt'. Long, P otary
By:
Deputy
REQUESTING PARTY:
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
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T
Plaintiff
VS
JOSEPH STANTON
Defendant(s)
No. 07-7195-CIVIL
CIVIL ACTION - LAW
PRAECIPE TO SATISFY JUDGMENT
Please mark the judgment in the above-entitled cause as paid and satisfied.
Respectfully Submitted,
/ By:
Date: I a
Amy yle 4#87062 / Daniel F. Wolfson #20617
Phili C. Warholic #86341 /David R. Galloway #87326
onilyn M. pie # 2 /Sarah E. Ehasz #86469
• 1259
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
Cc: JOSEPH STANTON
W&A File No. 154988831
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
PALISADES COLLECTION,L.L.C. No. 07-7195-CIVIL
ASSIGNEE OF AT &T
Plaintiff
CIVIL ACTION - LAW
VS.
JOSEPH STANTON
Defendant(s)
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a copy of the foregoing praecipe was
L f`t?
served this date by Regular Mail, Postage Pre-Paid on this day of
F-bi" , 20&
'IJ
JOSEPH STANTON
419 E COOVER ST
MECHANICS URG, PA 17055
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. Warholic #863411 David R. Galloway #87326
T tn M. Chippie / Sarah E. Ehasz #86469
olas, Jr. #201259
OLPOFF & 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. 154988831
tfr _?? " Eb ? _? CJ`s
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF AT &T
Plaintiff
VS
JOSEPH STANTON
Defendant(s)
No. 07-7195-CIVIL
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, SOVEREIGN BANK, discontinued, upon payment of your
costs only.
Respectfully Submitted,
Date: 11401a Am F. Do 1 / Daniel F. Wolfson #20617
hili C. Warholic 6341 David R. Galloway #87326
Tonilyn M. ippie 487852 / 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. 154988831
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-07195 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
STANTON JOSEPH
And now STEVE BENDER Sheriff or eputy Sheriff of
Cumberland County of Pennsylvania, who being duly worn according
to law, at 0009:00 Hours, on the 25th day of Janua , 2008, attached
as herein commanded all goods, chattels, rights, d bts, credits, and
moneys of the within named DEFENDANT ,
STANTON JOSEPH in the
hands, possession, or control of the within named arnishee
SOVEREIGN BANK 17 W HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DENISE BEECHER (CUSTOMER SERVICE REP) ,
personally three copies of interogatories togethe with 3 true
and attested copies of the within WRIT OF EXECUTI N and made
the contents there of known to Her .
Sheriff's Costs: So answers
Docketing .00
Service .00 Affidavit .00 R. Thomas Kl'ne
Surcharge .00 Sheriff of C mberland County
.00
00 /1300?,
01/28/2008
Sworn and Subscribed to
before me this day of By
A.D
utl? Sheriff
R. Thomas Kline, sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriffs Costs:
Docketing 18.00 Advance Costs: 150.00
Poundage 1.69 Sheriffs 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 Answers-
Post Pone Sale
Garnishee 9.00
Bad Check R. Thomas Kline, eriff
Postage
C?'
Total 85.99 ? /p 1/01
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7195 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 AT &
T, Plaintiff (s)
From JOSEPH STANTON, 419 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:
SOVEREIGN BANK, 17 W High Street, 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 $1,878.71
L.L. $.50
Interest from 11/29/07 at an interest rate of 6% per year -- To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Due. Prothy $2.00
Other Costs
Date: 1/22/08
(Seal)
REQUESTING PARTY:
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
el
Curtis W "Long, Protho
By:
Deputy
Supreme Court ID No. 86341