HomeMy WebLinkAbout08-1433IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
ISSUER OF THE AFFINITY CARD
Plaintiff No. 08- 1833 C' Zvi t Tit*
VS CIVIL ACTION - LAW
DEBORAH C DOUDEN
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), DEBORAH C DOUDEN , for want of pursuant to the
District Justice Transcript.
(X) Amount due $8,027.90
TOTAL $8,027.90, 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: ee--VL'
Am oyle #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
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, , 20-Q&-, JUDG =AS ABOVE.
Prothon tary/Clerk iv' ion
By:
Deputy
W&A File No. 178363290
46-
COMMONWEALTH OF PENNSYLVANIA
(Xl i I N TY C) F • CUMBERLAND
Mag- Dist. No..
09-3-05
MDJ Name: Hon.
MARS MARTIN
Address 507 N YORE ST
MECHANICSBURG, PA
Teiephone. (717) 766-4575 17055
ATTORNEY FOR PLAINTIFF :
- - d
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
5DISCOVER BANS ISSUER AFFINITY CARD
4660 TRINDLE RD APT/STE 300
NOLPOFF & ABRAMSON LLP
LCAMP HILL, PA 17011
VS.
DEFENDANT. NAME and ADDRESS
rDOUDEN, DEBORAH C
518 N MAIN ST
MECHANICSBURG, PA 17055
L
ANY F. DOYLE
4660 TRINDLE RD Docket No.: CV-0000441-07
4660 TRINDLE RD 3RD FL Date Filed: 11/27/07
CAMP HILL, PA 17011 Y
THIS IS TO NOTIFY YOU THAT:
FOR PLAINTIFF Date of Jud ment) 12/28/07
® Judgment was entered for: (Name) DISCOVER BANS ISSUER AFFINITY
® Judgment was entered against: (Name
in the amount of $ 8,027.9
DOUDEN, DEBORAH C
F Defendants are jointly and severally liable.
F1 Damages will be assessed on Date & Time
F This case dismissed without prejudice.
El Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
U Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment $ 7,902.90
Judgment Costs $ 125.00
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 8,027.901
Post Judgment Credits $ _i
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
- - AS; r?eLlR; „_
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE
A REQUEST.FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
4;2 ?` d 7" Date Magisterial Ds#' .fudge.
I certify that this is a true and correct copy of the record of the proceedings containing the judi
i 3 0.Y Date Magisterial District Judge
My commission expires first Monday of January, 2012 SEAL
AOPC 315-07
DATE PRINTED: 12/31/07 9:46:00 AM
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
ISSUER OF THE AFFINITY CARD No.
Plaintiff
VS CIVIL ACTION - LAW
DEBORAH C DOUDEN
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, Deborah
C Douden, above-named, is over 21 years of age; is last known to reside at 518 W Main St Mechanicsburg, County of
Cumberland, 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 d its Amendments.
Date:
Amy Doyle #87062 / Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #8732,6
i yn . ppie # 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
SWORN and SUBSCRIBED to before me this day of , 20 Qe
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Brands M. Moody. NotM Public
Hampden TV., Cunbedand C10U*
My Oorraftsion E)ires Nov. 30.2010
Member. Pennsylvania Association of Notaries
Notary Public
W & A File No. 178363290
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
ISSUER OF THE AFFINITY CARD No.
Plaintiff
VS
CIVIL ACTION - LAW
DEBORAH C DOUDEN
Defendant(s)
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I hereby certify that the precise address of Plaintiff is:
Discover Bank
6500 New Albany Road
New Albany OH 43054
and certify that the last known address of the within Defendant(s) is:
Deborah C Douden
518 W Main St
Mechanicsburg PA 17055
Date: r?"' ?Vb
Amy F. Do a #87062 / Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
1 yn Sarah E. Ehasz #86469
R N. o ert o as, r. #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. 178363290
O So
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
ISSUER OF THE AFFINITY CARD
Plaintiff
VS
DEBORAH C DOUDEN
Defendant(s)
No.
CIVIL ACTION - LAW
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: DEBORAH C DOUDEN
518 W MAIN ST
MECHANICSBURG, PA 17055
You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on
ahw ]no 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 $8,027.90, plus costs.
(X) District Justice transcript of judgment in civil action in the amount of $7,902.90, attorney's fees in the
amount of $0.00, interest in the amount of $0.00, 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
Date
If you have any questions rega4yD tic e, please contact the filing party.
le #87062 / Danie l F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
PP1e rah E. Ehasz #86469
9
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
Prothonotary??""
W&A File No. 178363290
OJL
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 TO 3149
DISCOVER BANK : IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
ISSUER OF THE AFFINITY CARD
Plaintiff
VS.
DEBORAH C DOUDEN
Def andant (s )
JUDGMENT NO. 08-1433
PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary: Please issue the Writ of Execution in the above-captioned
matter, in the amount of $ 8027.90.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against, DEBORAH C DOUDEN
518 W MAIN ST
MECHANICSBURG PA 17055
Defandant(s);
(3) and against BELCO COMMUNITY CREDIT UNION
located at 5304 CARLISLE BIKE
MECHANICSBURG PA' 17050 Garnishee(s);
(4) And index this writ
(A) against DEBORAH C DOUDEN
Defandant(s) and
(B) against, BELCO COMMUNITY CREDIT UNION ,Garnishee(s),
as a lis pendens against the real property of the Defandant(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 BELCO COMMUNITY CREDIT UNION , 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: $ 8027.90
Interest From: 03/04/2008 To Be Determined
At an interest rate of 6% per year
Total: $ 8027.90 Plus cosTt-4 interest _
David R. G [loway #$T9 Philip C. Warholic #86341
Sar' s?Ei3SZ--ad%s7/Robert N. Poles, Jr. #201259
Amy F. Doyle #87062
Mann Bracken LLP / Counsel for Plaintiff
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp 'Hill, PA 17011
Telephone: 866-253-0128 Fax: (717) 737-9051
PABGAR/PABANK FILE # 178363290
L1H?
MF'
rF
C
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r
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1433 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK, ISSUER OF THE AFFINITY
CARD, Plaintiff (s)
From DEBORAH C. DOUDEN, 518 W MAIN 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 BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA
17050 - 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.
GARNISHEE(S) as follows:
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 $8027.90
L.L. $.50
Interest FROM 3/4/08 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $54.25
Other Cost
Due Prothy $2.00
Plaintiff Paid
Date: MARCH 20, 2009
(Seal)
2" ? ?1- - - --
C s R. Lo onotary
By:
Deputy
REQUESTING PARTY:
Name DAVID R. GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLP
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 866-253-0128
Sheriffs Office of Cumberland County
R Thomas Kline ay??,cr of +?en?brtl??r Edward L Schorpp
Sheri r Solicitor
Ronny R Anderson V Jody S Smith
Chief Deputy OFFICE of THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
03/25/2009 03:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 25,
2009 at 1530 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Deborah C. Douden, in the hands, possession, or control of the with
named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Mechanicsburg, Cumberland County
Pennsylvania, 17050 by handing to Chris Reidlinger, Branch Manager, personally three copies of
interrogatories together with 3 true and attested copies of the writ of execution and'made the contents thft
of known to her.
The writ of execution and notice to defendant was mailed on 03-27-09 to Deborah C. Douden, 518 W Mai
Street, Mechanicsburg, PA 17055.
08-1433 So Answers
Discover Bank
vs 00 "Ile
Deborah C. Douden R, homas 4Klinoe
Sheriff
By
D puty Sheriff
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P?3 _ ?_..
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C?'?
Cam. '?:.
y SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ?;r ?; ,, rear -
Jody S Smith
Chief Deputy n _.. , 1 L
iU i•? '
L? Edward L Schorpp
Solicitor`
Discover Bank
vs. Case Number
.
Deborah C Douden 08-1433
SHERIFF'S RETURN OF SERVICE
03/25/2009 03:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 25,
2009 at 1530 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Deborah C. Douden, in the hands, possession, or control of the
within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Mechanicsburg, Cumberland
County, Pennsylvania, 17050 by handing to Chris Reidlinger, Branch Manager, personally three copies of
interrogatories together with 3 true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on 03-27-09 to Deborah C. Douden, 518 W
Main Street, Mechanicsburg, PA 17055.
04/08/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $93.11 SO ANSWERS,
April 08, 2010 RON R ANDERSON, SHERIFF
Sharon R. Lantz
?a. sold ?d
ecc? 7s?7d
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1433 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK, ISSUER OF THE AFFINITY
CARD, Plaintiff (s)
From DEBORAH C. DOUDEN, 518 W MAIN 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 BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA
17050 - 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.
GARNISHEE(S) as follows:
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 $8027.90
L. L. $.50
Interest FROM 3/4/08 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $54.25
Other Cost
Plaintiff Paid
Date: MARCH 20, 2009
Due Prothy $2.00
Cu is R. Long, P of y
(Seal)
By:
Deputy
REQUESTING PARTY:
Name DAVID R. GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLP
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 866-253-0128
1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
DISCOVER BANK
ISSUER OF THE AFFINITY CARD
Plaintiff
vs.
DEBORAH C. DOUDEN
Defendant(s)
CIVIL DIVISION
No. 08-1433 CIVIL TERM
a Z•
--t cu?-
f i
PRAECIPE FOR ENTRY FOR OF
APPEARANCE
Filed on behalf of DISCOVER BANK, ISSUER
OF THE AFFINITY CARD
Counsel of Record for this party:
STOCK & GRIMES, LLP
Edward Stock, Esquire
I.D.#13657
804 West Avenue
Jenkintown, PA 19046
(215) 576-1900
.r t Ift
STOCK & GRIMES, LLP
By: Edward Stock, Esquire
I.D.#13657
804 West Avenue
Jenkintown, PA 19046
(215) 576-1900
DISCOVER BANK
ISSUER OF THE AFFINITY CARD
VS.
DEBORAH C. DOUDEN
Defendant(s)
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION-LAW
NO. 08-1433 CIVIL TERM
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my Appearance as co-counsel on behalf
of the Plaintiff in regard to the above matter.
DATE: 6/20/12
EDWARD S OCK,
STOCK & GRIMES, LLP
BY: Edward Stock, Esquire
I.D.#13657
804 West Avenue
Jenkintown, PA 19046
(215) 576-1900
DISCOVER BANK
ISSUER OF THE AFFINITY CARD
p' f i r,
`':Y`'
Attorney for P1°aniff' ` TT
"RLAND COUNT ti.
PDIE11SYLVAN1A
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
CIVIL ACTION-LAW
VS.
DEBORAH C. DOUDEN
Defendant(s)
NO. 08-1433 Civil Term
Y
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly mark the Judgment entered in regard to the
above captioned case satisfied of r c
DATE: 6/20/12
EDWARD OC ,