HomeMy WebLinkAbout08-4965IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
vs.
Plaintiff
DORIA N MAHONEY
Defendant(s)
No. 08 - Alq&6 CiVi l TrM
CIVIL ACTION - LAW
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), Doria N Mahoney , pursuant to the attached
Exemplified Judgment Record.
( X) Amount due
TOTAL
$8,488.83
$8,488.83,
( 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: J
p C. Warholic #86341 /
Sarah E. Ehasz #86469 /
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
NOW, , 200, J IS E D AS ABOVE.
Pro onotary/C ivi Div' ion
By:
Deputy
FILE NO. 175528289
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
Plaintiff
VS.
DORIA N MAHONEY
Defendant(s)
id R.
PRAECIPE FOR ENTRY OF EXEMPLIFIED JUDGMENT
To the Prothonotary:
Please enter the attached Exemplified record as a civil judgment.
Respectfully Submitted,
Date: S
No. v5,-CJ'I1 4c.4(w4
CIVIL ACTION - LAW
C. Warholic #86341 /
arah E. Ehasz #86469 /
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. 175528289
COMMONWEALTH OF PENNSYLVANIA,
County of Monroe ss:
I,..George..J....Warden ............. _.................. Prothonotary Of the Court of
Common Pleas in and for said County, do hereby certify that the
foregoing is a full, true and correct copy of the whole record of the
case thereon stated, wherein .................. _........ _...... _...... _.............. _.............. _.... _.............................. ...........
1Y1BNA.A.MERICAAANK,N.A.. PLAINTIFF V 12QRIA N
MAHONEY, DEFENDANT, so full and entire as the same remains of
record before
the said Court, at No...9117..of ..............Civil.............................. Term,..A.D..2001 ........................
........................
In Testimony Whereof, I have hereunto set my hand and affixed the seal of said Court, this
...................................1.4 r"....1;?AY..QF..APIUL......................................................... ._............ _.............. 2008
Prothonotary
1,...... .................................R..anald.E.. Vican...................................................................................President Judge of the 43rd
Judicial District, composed of the Court of Common Pleas of said County and State do certify
that
............... ................... ............... George..J....W.arden,.P.rothonotary.................................. _........ _............... _..................... _........... _.........................................
by whom the annexed record, certificate and attestation were made and given, and who, in his
own proper handwriting, thereunto subscribed his name and affixed the seal of the Court of
Common Pleas of said County, was at the time of so doing and now is Prothonotary in and for
said County of Monroe in the Commonwealth of Pennsylvania, duly commissioned and
qualified; to all of whose acts, as such, full faith and credit are and ought to be given, as well in
Courts of Judicature as elsewhere, and that the said record, certificate and attestation are in due
form of law and made by the proper officer. I
COMMONWEALTH OF PENNSYLVANIA,
County of Monrof ss:
President Judge
1,...................................... George-L.W...arden......................................................................_._....._...........................Prothonotary of
the Co;:rt of Common Pleas in srd for said County, do certify that the Honorable
...............
............... Ronald..iM....V..ican.... _....................... _.... , by whom the foregoing attestation was made, and who has
thereunto subscribed his name, was at the time of making thereof and still is President Judge of
the Court of Common Pleas, in all divisions in and for said County, duly commissioned and
qualified; to all whose acts, as such, full faith and credit are and ought to be given, as well in
Coiuts of Judicature as elsewhere.
In Testimony.. Whereof, I have hereunto..set my hand and affixed the seal of said
Court, this .............1.4T."...DAY...OE..APRIL.,.20.0.8.............................................. _..........................................................................
Prothonotary
Among the Records and Proceedings enrolled in the Court of Common Pleas in and for
the County of Monroe in the Commonwealth of Pennsylvania, to No.,..Q.l...7 CV e,p,.......2007
is contained the following:
COPY OF ................ ................ CONTINUATION....._DOCKET ._ENTRY ................ ..............................
COMMONWEALTH OF PENNSYLVANIA,
County of Monroe I SS:
I,-.George-.J.-Warden ................................. Prothonotary Of the Court of
Common Pleas in and for said County, do hereby certify that the
foregoing is a full, true and correct copy of the whole record of the
case thereon stated, wherein .............................................................................................................................
11! I1.N&AMERLCAJ3AN1t.,
MAHONEY, DEFENDANT, so full and entire as the same remains of
record before
the said Court, at No...91.97..af ..............Civil............................... Term,..A.11..2007 ........................
In Testimony Whereof, I have hereunto set my hand and affixed the seal of said Court, this
.......................1.4..`...H DAY-OF ...APRIL, 2008
.......................................................................................
Prothonotary
1, ...................... ................ Ronald.E....Vicitn................................................................................... President Judge of the 43rd
Judicial District, composed of the Court of Common Pleas of said County and State do certify
that
................................. G eorge..J....W.arden,.. Prothono.Wy.....................................................................................................
by whom the annexed record, certificate and attestation were made and given, and who, in his
own proper handwriting, thereunto subscribed his name and affixed the seal of the Court of
Common Pleas of said County, was at the time of so doing and now is Prothonotary in and for
said County of Monroe in the Commonwealth of Pennsylvania, duly commissioned and
qualified; to all of whose acts, as such, full faith and credit are and ought to be given, as well in
Courts of Judicature as elsewhere, and that the said record, certificate and attestation are in due
form of law and made by the proper officer.
w
.................. ...........................................................................................................
President Judge
COMMONWEALTH OF PENNSYLVANIA,
County of Monro ss:
I, ....... :.............................. G.earge..J....y.V..arden. ............................................................................................................ Prothonotary of
t ;; Court of C"om7mn Pleas in and for said County, do certifv that the Honorable ........_.
..............................
................ R.onald..R...Vican................................... , by whom the foregoing attestation was made, and who has
thereunto subscribed his name, was at the time of making thereof and still is President Judge of
the Court of Common Pleas, in all divisions in and for said County, duly commissioned and
qualified; to all whose acts, as such, full faith and credit are and ought to be given, as well in
Courts of Judicature as elsewhere.
In Testimony... Whereof, I have her:eunto..set my hand and affixed the seal of said
Court, this .............. 1.4TH..DAY..OE.AP.RIL..,.2.0.0.8............................................... ...........................................................................
Prothonotary
Among the Records and Proceedings enrolled in the Court of Common Pleas in and for
the County of Monroe in the Commonwealth of Pennsylvania, to No,..91.87 CV Term......... 2007
is contained the following:
COPY OF CONTINUATION......DOCKET..ENTRY ..............................................
15224204142008 Monroe County Pennsylvania Page 2
PYS835 Docket Entries 4/14/2008
Case No 2007-09187
FIA CARD SERVICES N A (VS) MAHONEY DORIA N
Date
Filed
- - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - -
1 10/16/07 COMPLAINT WITH NOTICE, FILED. KDM
016 Image page(s) exist(s) for this entry
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
2 11/16/07 SHERIFF'S RETURN - COMPLAINT,FILED. KDM
COSTS-$57.71 PD.PLFF.
001 Image page(s) exist(s) for this entry
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
3 12/28/07 PRAECIPE FOR DEFAULT JUDGMENT, FILED. ENTERED IN FAVOR OF
FIA CARD SERVICES NA FKA AMERICA BANK NA
AND AGAINST DORIA N MAHONEY
IN THE AMOUNT OF $8488.83 PLUS INTERESTS AND COSTS
EODIE COPIES MAILED (MB)
P. WARHOLIC, D. MAHONEY
009 Image page(s) exist(s) for this entry
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - -
15224204142008 Monroe County Pennsylvania
PYS835 Docket Entries
Cover Sheet
Case No 2007-09187
Plaintiff :
FIA CARD SERVICES N A F/K/A
MBNA AMERICA BANK N A
** (VS) **
Defendant:
MAHONEY DORIA N
CERTIFIED FROM THE RECORD
? ?day ofiAZ 20
7T i
*#vnotary, Common Pleas v
43rd Judicial Disb*
Monroe County, PA
4/i4/2008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
No.
Plaintiff
VS CIVIL ACTION - LAW
DORIA N MAHONEY
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, Doria N
Mahoney, above-named, is over 21 years of age; is last known to reside at 3330 Emerald Blvd Long Pond, County of
Monroe, 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: 8 S 0?
le ilip C. Warholic #86341 /
qRoSarah E. Ehasz #86469 rt o a r. 01259
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
h
SWORN and SUBSCRIBED to before me this day of , 20
\IJ
(IV.vlj
Notary Public
OWMONWEALTH OF PENNSYLVANIA
Nom w Sod
Airy R. Wise, NOWY Pd*
a"wimid 00"
HoVdan
MY conff"M "EVwn Nair 30, 2010
Member, Panr&*anla Anoomlon of Notaries
Affidavit of Non-Military File No. 175528289
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
Plaintiff
VS.
DORIA N NL HONEY
Defendant(s)
Commonwealth of Pennsylvania
County of CUMBERLAND
:ss.
NO.
CIVIL ACTION - LAW
AND NOW, TO WIT, this day of , 20 , comes the undersigned who being duly
sworn according to law, deposes and says that they are the Attorney for the Plaintiff in the above-captioned action; that
the judgment is valid, enforceable and unsatisfied.
ilip C. Warholic #86341 /
David R. G low #8732 ah E. Ehasz #86469 /
o ert o as, 259
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
SWORN and SUB CRIBED to
befo me this da
of 20
Notary lic
COMMONWEALTH OF PENNSYLVANIA
E Notarial Seal
Amy R. Wtea, Notary Pulc
My Owffl"w FEVko
mwAw. Penns Mma Aasock*W of WON
Affidavit of Foreign Judgments File No. 175528289
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
No.
Plaintiff
VS
CIVIL ACTION - LAW
DORIA N MAHONEY
Defendant(s)
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I hereby certify that the precise address of Plaintiff is:
655 Paper Mill Road
De5-013-02-02
Wilmington DE 19884
and certify that the last known address of the within Defendant(s) is:
Doria N Mahoney
3330 Emerald Blvd
Long Pond PA 18334
Date:
062 / Philip C. Warholic #86341 /
avi=G allow #8 Sarah E. Ehasz #86469 /
Robert N. Polas, Jf. #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
Certificate of Residence File No. 175528289
`
;-; tt1
n
? w drn
v
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A.
Plaintiff
VS.
DORIA N MAHONEY
Defendant(s)
No.
CIVIL ACTION - LAW
NOTICE OF JUDGMENT
( x ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of
$8,488.83, on a Ala , 20D
(x) A copy of all documents filed with the Prothon in support o e within judgment is/are attached.
By: MEW
If you have any questions regarding this Notice, please co t the filing patty.
Date: C51,
Philip C. Warholic #86341 /
David R. Gallo #87326 ah E. Ehasz #86469 /
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
This Notice is given in accordance with Pa.R.C.P. 236.)
NOTICE SENT TO:
Doria N Mahoney
3330 Emerald Blvd
Long Pond PA 18334
Notice of Judgmnt wo Docket No File No. 175528289
234
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 TO 3149
FIA CARD SERVICES, N.A.
FKA, MBNA AMERICA BANK, N.A.
Plaintiff
VS.
DORIA N MAHONEY
Defandant(s)
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 08-4965-CIVIL TE
PRAECIPE FOR WRIT OF EXECUTION
To the Prothonotary: Please issue the Writ of Execution in the above-captioned
matter, in the amount of $ 8,480.83.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against, DORIA N MAHONEY
3330 EMERALD BLVD
LONG POND PA 1833#
Defandant (s) ;
(3) and against SOVEREIGN BANK '
located at 17 W. HIGH STREET
CARLISLE PA 17013 Garnishee(s);
(4) And index this writ
(A) against DORIA N MAHON?Y
Defandant(s) and
(B) against, SOVEREIGN BANK ,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)***GRRNISH ONLY***
You are directed to attach the property of the Defendant(s) not levied upon in
the possession of SOVEREIGN BANK , Garnishee(s)
All accounts including but not 1 mited to all savings, checking and other
accounts, certificates of deposi , notes receivables, collateral, pledges,
documents of title, securities, coupons and safe deposit boxes.
Amount Due: $ 8,488.83
Interest From: 12/28/2007 To Be Determined
At an interest rate of 6% per ye r
Total: $ 8,488.83 Plus cos s & interest (total includes post judgment credits).
Da id R. G loway #87326/Ph-l*ip C. Warholic #86341
Sarani sz 6469/Robert N. Polas, Jr. #201259
Amy F. Doyle #87062
Ma n Bracken LLC / Counsel for Plaintiff
Th Successor by Merger to Wolpoff & Abramson, LLP
an; Eskanos & Adler, P. C.
4660 Trindle Road, Suite 300, Camp Hill, PA 17011
Telephone: (717) 303-6700 Fax: (717) 737-9051
PABGAR/PABANK FILE # 175528289',
0 og Q ? t
cy -p
--U ? 4
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4965 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIA CARD SERVICES, N.A., f/k/a MBNA AMERICA
BANK, N.A., Plaintiff (s)
From DORIA N. MAHONEY, 3330 Emerlad Blvd, Long Pond, PA 18334
(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 limitedto all savings, checking and other accounts, certificates of
deposit, notes receivables, collateral, ledges, documents of title, securities, coupons and safe deposit
boxes.
and to notify the garnishee(s) that: (a) a attachment has been issued; (b) the gamishee(s) is enjoined from
paying any debt to or for the account of he defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not evied 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 state.
Amount Due $8,488.83 L.L. $.50
Interest from 12/28/07 at an interest rate of 6$ per year - To Be Determined
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 11/25/08
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs to be added
C R. Long, P notary
By:
Deputy
Name DAVID R. GALLOWAY, ESQ0RE
Address: MANN BRACKEN LLC
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87326
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-04965 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
MBNA AMERICA ABANK N A
VS
MAHONEY DORIA N
And now TIMOTHY R. BLACK Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:00 Hours, on the 5th day of December-, 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
MAHONEY DORIA N
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 17 W HIGH ST
in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JULIE MYERS (CUSTOMER SVC MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
true
and made
the contents there of known to Her
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00 ?/zAf/
12/08/2008
Sworn and Subscribed to
before me this day of By ?j o`zo"`•
eputy Sheriff
A.D
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
MBNA AMERICA BANK, N.A. NOW KNOWN AS FIA CARD SERVICES
Plaintiff NO. 08-4965
vs.
DORIA N MAHONEY
Defendant
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.
Dated: l !
MB File No. 175528289
Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259
MANN BRACKEN LLP
The Successor by Merger to Wolpoff & Abramson, LLP
and Eskanos & Adler, PC
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., Suite 300
Camp Hill, PA 17011
(717) 303-6700
cc: SCOTT M. AMORI
513 SARAH STREET
STROUDSBURG, PA 18360
Respectfully Submitted,
C
'?' %42
Y,!
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4965 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FIA CARD SERVICES, N.A., f/k/a MBNA AMERICA
BANK, N.A., Plaintiff (s)
From DORIA N. MAHONEY, 3330 Emerlad Blvd, Long Pond, PA 18334
(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, securities, 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 $8,488.83
L.L. $.50
Interest from 12/28/07 at an interest rate of 6$ per year -- To Be Determined
Atty's Comm %
Atty Paid $56.00
Plaintiff Paid
Date: 11x25/08
(Seal)
Due Prothy $2.00
Other Costs to be added
2
Cu is R. Long, Pr o ry
By:
Deputy
REQUESTING PARTY:
Name DAVID R. GALLOWAY, ESQUIRE
Address: MANN BRACKEN LLC
4660 TRINDLE ROAD, SUITE 300
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87326
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
c?ITUWrit is returned ABANDONED, no action taken in six months
.
=1heriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 86.58
Docketing 18.00 63.42
Poundage 1.70
Law Library .50 Refunded on 06/16/09
Prothonotary 2.00
Mileage 4.50
Surcharge 30.00
Levy 20.00
Postage .88
Garnishee 9.00 ??11 So Answers,
$ 86.58 ?-????°? `?`
R. Thomas Kline, Sheriff
By
1/ Sharon R. Lantz
E O fi d 1 - 330 9001
r
C 10/`17
i c:. ,? L 59.0