HomeMy WebLinkAbout08-1946
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTIOML.L.C.
Plaintiff No. 6S- lg4t O N11 Term
VS CIVIL ACTION - LAW
ANGELA L FINLEY KHAN
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), ANGELA L FINLEY KHAN , for want of pursuant to
the District Justice Transcript.
(X) Amount due $923.88
TOTAL $923.88, 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 co y of the notice is attached. '?3/11/6?- I Date:
Amy F. ogle #8f062 / 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, MUC11 , 20-C&-, JUDG IS ENTE AS ABOVE.
r big
Pro onotary/Cler vil Di lion
By:
Deputy
W&A File No. 17-0503053
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Mag. Dist. No.:
09-2-02
MDJ Name: Hon.
JESSICA BBENPBAEER
Address: 18 N HANOVEjt ST STE 106
CARLISLE, PA
Telephone: (717 ) 240-6564 17013
PALISADES COLLECTION, LLC
4660 TRINDLE ROAD APT/STS 300
%WOLPOFF & ABRAMSON, LLP
CAMP HILL, PA 17011
THIS IS TO NOTIFY YOU THAT:
Judgment: FOR PLAINTIFF
3''--? ?1
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rPALISADES COLLECTION, LLC
4660 TRINDLE ROAD APT/STN 300
%VOLPOFF da ABRAMSON, LLP
LCAMP HILL, PA 17011 J
VS.
DEFENDANT: NAME and ADDRESS
rFINLEY ESAN, ANGELA L ?
274 W RIDGE ST
CARLISLE, PA 17013
L J
Docket No.: CP-0000409-07
Date Filed: 12/20/07
_ (Date of Judgment) 1/31/08
® Judgment was entered for: (Name) PALISADES COLLECTION, LLC
Judgment was entered against: (Name) FINLEY IRAN, ANf3ELA L
in the amount of $ 923.8
? Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed without prejudice.
Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127
? Portion of Judgment for physical damages arising out of
residential lease $
Amount of Judgment
Judgment Costs
Interest on Judgment
Attorney Fees
Total
$ 846.38
$ 77•
$ .00
$ .1010
$ 923.88
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/rRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE 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
3/-08 Date
, Magisterial District Judge
I certify that this is a tru a , rrect copy of the record of the proceedings containing the judgment.
3?jt% Date Magisterial District Judge
My commission expires first Monday of January, 2012 SEAL
AOPC 315-07
DATE PRINTED: 1/31/08 9:09:00 AN
v
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
No.
Plaintiff
VS CIVIL ACTION - LAW
ANGELA L FINLEY KHAN
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, Angela L
Finley Khan, above-named, is over 21 years of age; is last known to reside at 274 W Ridge St Carlisle, 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 and its Amendments.
Date: -3
my F. Doyle 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
SWORN and SUBSCRIBED to before me this Alw- day of ff)Da , 200Y
.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seat--"- --
Brand M. Moody, Notary Public
Aden Twp nd ty Notary Public
won Evres Nov. 30, 2010
Member, Pennsylvania Association of Notaries
W & A File No. 170503053
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
Plaintiff
VS
ANGELA L FINLEY KHAN
Defendant(s)
No.
CIVIL ACTION - LAW
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:
Angela L Finley Khan
274 W Ridge St
Carlisle PA 17013
Date: 3 a
Amy F. Doyle #8 *62 / 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
W&A File No. 170503053
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
- No.
Plaintiff
VS
CIVIL ACTION - LAW
ANGELA L FINLEY KHAN
Defendant(s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: ANGELA L FINLEY KHAN
274 W RIDGE ST
CARLISLE, PA 17013
You are herggby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on
3Ia7/o8 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 $923.88, plus costs.
(X) District Justice transcript of judgment in civil action in the amount of $795.02, attorney's fees in the
amount of $0.00, interest in the amount of $51.36, 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: co
P thono
If you have any questions regarding this Notice, please contact the filing party.
Date: cZ 1
Amy F. Doyle 7062 / 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
W&A File No. 170503053
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
PALISADES COLLECTION,L.L.C. IN THE COURT OF COMMON PLEAS OF
ASSIGNEE OF INTERNATIONAL PORTFOLIO CUMBERLAND COUNTY, PENNSYLVANIA
ASSIGNEE OF HOUSEHOLD BANK
Plaintiff
VS.
JUDGMENT NO. 08-1946
ANGELA L FINLEY KHAN
PRAECIPE FOR WRIT OF EXECUTION
Defendant(s) (MONEY JUDGMENT)
To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $923.88.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against,ANGELA L FINLEY KHAN located at 274 W RIDGE ST, CARLISLE, PA 17013, Defendant(s)
(3) and against, COMMERCE BANK located at 20 NOBLE BLVD, CARLISLE, PA 17013, Garnishee(s);
(4) and index this writ
(a) against, ANGELA L FINLEY KHAN , Defendant(s) and
(b) against, COMMERCE 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
COMMERCE BANK located at 20 NOBLE BLVD, CARLISLE, PA 17013, 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 $923.88
Interest from 03/27/2008 To Be Determined
At an interest rate of 6% per year
Total $923.88 Plus costs & interest
Date:
Amy ?F,.Doyle #87 62 DanielPhilioli #863 David R. Gallo
Toniippie '8785 .
Robert N. Poias, 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 170501051 XXX-XX-9161
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1946 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
INTERNATIONAL PORTFOLIO, assignee of HOUSEHOLD BANK, Plaintiff (s)
From ANGELA L. FINLEY KHAN, 274 W. Ridge Street, Carlisle, PA 17013
(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:
COMMERCE BANK, 20 Noble Blvd, 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 $923.88
L.L. $.50
Interest from 3/27/08 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 4/21/08
(Seal)
Due Prothy $2.00
Other Costs
Cur's R. Long, Pr onota
By:
REQUESTING PARTY:
Name DAVID R. GALLOWAY, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Deputy
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87326
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-01946 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
FINLEY KHAN ANGELA L
And now DAWN KELL
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:41 Hours, on the 25th day of April , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
FINLEY KHAN ANGELA L
hands, possession, or control of the within named Garnishee
COMMERCE BANK 20 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
KRISTIN EGOLF (CUSTOMER SERVICE REP)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
, in the
true
and made
So
rrAAl?
.00
.00
.00 R. Thomas Kline
.00 Sheriff of Cumberland County
.00
04/28/2008
Sworn and Subscribed to
before me this day of
, A.D
BY Z)?, d . 61-?-
Deputy Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF INTERNATIONAL PORTFOLIO
ASSIGNEE OF HOUSEHOLD BANK
Plaintiff
VS
ANGELA L FINLEY KHAN
Defendant(s)
No. 08-1946
CIVIL ACTION - LAW
INTERROGATORIES TO GARNISHEE
TO: COMMERCE BANK
20 NOBLE BLVD
CARLISLE, PA 17013
PURSUANT TO RULE 3253 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED
TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARA'T'ELY AND FULLY. PLEASE
COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE CREDITOR'S EFFORTS TO SATISFY
THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOMS).
IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHEE
A. You are required to file answers to the following interrogatories within twenty (20) days after service
upon you. Failure to do so may result in judgment against you.
issued.
B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was
C. "You" means the main office and all branch offices, ,representatives, employees, and agents of your
organization.
D. By service of the Writ of Execution upon you, all property of the Defendant(s). subject to attachment
which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into
your possession thereafter.
E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented
as you receive further or additional information.
F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate
is to be used, it should be identified as such, and an explanation should be given as to the basis on which the estimate is
made, and the reason the exact information cannot be furnished.
G. Where knowledge or information in possession of a party is requested, such request includes knowledge
of the party's agents, representatives, and attorneys.
W&A File, No 1705010S' NW-XX-9161
INTERROGATORIES TO GARNISHEE
DEFENDANT'('S) - ANGELA L FINLEY KHAN
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent time, state whether or not the
Defendant(s) maintains any checking, savings, lines of credit, certificate of deposit's or other depository aooounts with
your institution. If so, state the identification numbers of those accounts, and the amount or amounts the Defendant(s) has
in each account. If the Defendant(s) maintains any of these jointly with any other person, or persons, give their name and
address. N o
IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit
accounts? If yes, please state the identification numbers of those accounts.
2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the
defendant have funds on deposit in an account in which funds are deposited electronically on. a recurring basis and which
are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or
federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each
exemption and the entity electronically depositing those funds on a recurring basis. N o
3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the
defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds,
did not exceed the amount of the general monetary exemption under 42 Pa.C.S. $123? If so, identify each account.
No
4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money
or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any
claim of the defendant against you? N o
5. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the
Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the
box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the
Defendant(s) maintains any of these jointly with any other person or persons give their full name and address.
No
W&A File Nn. 170')0105'; XXX-XX-9161
6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or
not Defendant(s) owns any personal property that was in your possession and/or control If so, include a full description of
all personal property giving full value and present location. State also whether or not there are any encumbrances or liens
holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the
Defendant(s) owns any personal property jointly with any person or persons, give names and address.
No
7. OTHER ASSETS: At the time you were served or at any subsequent time, did you imow of the existence of
any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all
details concerning those asset. N o
8. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you
hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s)
the nature of the property including its value and the interest of Defendant(s). N o
9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or processing fees charged by you
against the Defendant(s) or account(s) of the Defendant(s) for the completion of this Answer. If yes, outline the exact
amount of any fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer.
No
Date:
Amy F. Doyle #002 /Daniel F. n #
Philip C. Warholic 34 avid R. Gak oway #8732
Tonilyn M. Chippie #87852 / zz 9
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. Nn 170`50'10'51 XXX-XX-91I61
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating
to unsworn falsifications to authorities, that he/she is Jennifer Hilbish
(Name)
Levy Specialist of Commerce Bank/Harrisburg N.A, garnishee herein,
(Title) (Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best o:
belief.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION,L.L.C. No. 08-1946
ASSIGNEE OF INTERNATIONAL PORTFOLIO
ASSIGNEE OF HOUSEHOLD BANK
Plaintiff
VS
ANGELA L FINLEY KHAN
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, COMMERCE BANK, discontinued, upon payment of your
costs only.
Respectfully Submitted,
Date:
341
Amy F. Doyle #87062 arholiA7#886469
David R. Galloway #87 26 /Sarah E. Eh/
Robert
N. Polas, Jr. #201259
Mann Bracken LLC
The Successor by Merger to Wolpoff & Abramson, L.L.P.
and Eskanos & Adler, P.C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: (717) 303-6700
Counsel for Plaintiff
File No. 170503053
C= 41
C? 013
= 94, " ; ...
O i
5
1. t C.71
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Docketing
Poundage,
Advertising
Law Library
Prothonotary
Milage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
Advance Costs: 150.00
116.39
18.00 33.61
1.89
Refunded on 10/30/08
.50
2.00
5.00
40.00
40.00
9.00 So Answers,
116.39 ? l?Ji3Jc? Y ??,.,
R. Thomas Kline, Sheriff''"
By
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1946 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
INTERNATIONAL PORTFOLIO, assignee of HOUSEHOLD BANK, Plaintiff (s)
From ANGELA L. FINLEY KHAN, 274 W. Ridge Street, Carlisle, PA 17013
(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:
COMMERCE BANK, 20 Noble Blvd, 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 $923.88
L.L. $.50
Interest from 3/27/08 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 4/21/08
Due Prothy $2.00
Other Costs
. d, (0?
Curti . Long, P otary(Seal)
REQUESTING PARTY:
Name DAVID R. GALLOWAY, 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. 87326
By:
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
PALISADES COLLECTION,L.L.C.
ASSIGNEE OF HOUSEHOLD BANK
Plaintiff
VS.
ANGELA L FINLEY KHAN
Defendant (s)
COUNTY, PENNSYLVANIA
: No. 08-1946
CIVIL ACTION - LAW
PRAECIPE TO SATISFY JUDGMENT
To the Protonotary:
Please mark the judgment in the above-entitled cause as paid and satisfied.
Respectfully Submitted,
Date: /Z (X/
By:
David R. Ga loway #873 Philip C. Warholic #86341
SaraN E. MI
azz y86469 obert N. Polas, 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: (717) 303-6700 Fax: (717) 737-9051
PRAECV/*PLP2 FILE # 170503053
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
PALISADES COLLECTION,L.L.C.
ASSIGNEE OPlaintiffLD BANK
VS.
ANGELA L FINLEY KHAN
Defendant (s)
CERTIFICATE OF SERVICE
COUNTY, PENNSYLVANIA
: No. 08-1946
CIVIL ACTION - LAW
The undersigned does hereby certify that a true and correct copy of the Praecipe
was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on
ANGELA L FINLEY KHAN
29 S EAST ST
CARLISLE PA 17013-2517
Davi%-f* Gi oway #8732 Philip C. Warholic #86341
ara
;Fasz
9/Robert N. Polas, Jr. #201259
Amy F. Do le #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: (717) 303-6700 Fax: (717) 737-9051
PACERP/*PLP2 FILE # 170503053
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