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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 r ? 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 ra ?? r.? ? > ?? - , € t? _ ?? i- P?3 _ ?_.. ..- ?.~. 3 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 ,