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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 [i -- ? ? ? -- ?? ...., ?.? P.'? ::. ? ?a ?: i? ? y i i ? ? ? ? ry '1 n.+` j _ ?rv ?? ? ? p _ "? ? , a,.,,.,?? -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 R . k 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 llf 0 i C, p -? ,Y i, ? f71? j F ?5 m BUG 44 4 li L7 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 r•a -s t} .. 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> c::D - -a ? .• i L ....wv 'w '1 .? ? F 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 O ?W ?I a ?I W ?V ?l O O 8 a 0 ?' 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 r' 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 t'`l 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 n -4Q6 g o 0 ? a 4 C:) w?C W 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 laudia A. Brewbaker E F .E d E Z Nvr ow w 'JliNnoi ?] 12i3ElWfl i 331H3NS 3H1 30 331J30 c' N ? o f ri1 = ra j A cn . fri r , { LL ? .Uv C'- 4 V\ C*--I 1, 973 /rw .2,701.z a i 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