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HomeMy WebLinkAbout08-7553? -w Unifund CCR Partners assignee of Palisades Collection, LLC c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 Plaintiff Vs. JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Defendant To the Prothonotary of CUMBERLAND County: In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: Z)8' rI-ss63 avd ILxp- PRAECIPE FOR ENTRY OF JUDGMENT 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: B) Amount of Judgment: $3,705.93 C) Interest From: 2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3) I hereby certify that the address of the plaintiff is: Unifund CCR Partners assignee of Palisades Collection, LLC c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 4) I hereby certify that the address of the defendant is: JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 1729 Pittston Ave, r?4C;tMONWEALTH OF PENNSYLVANIA rr)i INTY OP- CUMBERIJUM Mag. Dist. No.: 09-3-02 MDJ Name: Hon. VIVIAN COHICS Address: p0. BOX 155 27 W BIG SPRING AVZ NEMVILLZ, PA Telephone: (717 ) 776-3187 17241 ATTORNEY FOR PLAINTIFF : MICHAEL F. RATCHFORD 1729 PITTSTON AVZ SCRANTON, PA 18505 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAMEandADDRESS rDNIFu CCR PARTNERS 1729 PITTSTON AVZ C/O ABRAHA1L88N & ASSOC LSCRANTON, PA 18505 J VS. DEFENDANT: NAME and ADDRESS rSBLL, JOHN G 315 NCALLISTER CIURC8 RD CARLISLE, PA 17015 L J Docket No.: CV-0000127-08 Date Filed: 8/04/08 THIS IS TO NOTIFY YOU THAT: Judgment: DZFAULT JODGIQNT PLTF (Date of Judgment) 10/08/08 Judgment was entered for: _ (Name) lUNI7UW CCR PARTNERS ® Judgment was entered against: (Name) ZZLL, JOHN G . in the amount of $ 3,705 9 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 Fj Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 3,590.23 Judgment Costs $ 115.75 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 3,705.93 Post Judgment Credits $ Post Judgment Costs $ I 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 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. My commission expires first Monday of January, 2012 SEAL AOPC 315-07 DATE PRINTED: 10/08/08 11:10:00 AN ?+ Unifund CCR Partners assignee of Palisades Collection, LLC c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 Plaintiff VS. JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Defendant In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): JOHN G KELL is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): JOHN G KELL is(are) older than eighteen years of age; That the employment status of the defendant(s): JOHN G KELL is(are) unknown. y? t7 Tr Co ro 7i c...:; .< Scranton, PA 18505 570-558-5510 Ext. 101 Attorney ID 86285 Unifund CCR Partners assignee of Palisades Collection, LLC c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff : NO: VS. NOTICE OF FILING JUDGMENT JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Defendant Notice is herby given that a money judgment in the above-captioned matter ha been entered against you in the amount of $ 3. 170E, q3 on /o't. of By: /'91Z4 If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 1729 Pittston Avenue Scranton, PA 18505 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Unifund CCR Partners assignee of Palisades Collection, LLC CIVIL DIVISION Plaintiff VS. JOHN G KELL Defendant NO: 08-7553 PLAINTIFF'S MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, Unifund CCR Partners assigneeof Palisades Collection, LLC, by and through its attorneys, Edwin A. Abrahamsen &Associates, P.C., files its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: 1. Plaintiff, Unifund CCR Partners assigneeof Palisades Collection, LLC,obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. 2. On January 07, 2009, Plaintiff served Defendant with Interrogatories in Aid of Execution on the subject judgment. (See Interrogatories in Aid of Execution dated January 07, 2009, attached hereto and marked Exhibit "A ". ) 3. Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. 4. On February 27, 2009, Plaintiff sent a letter to remind the Defendant of the past due responses and his duty to provide the same. (See, Correspondence to Defendant, attached hereto and marked Exhibit "B".) 5. Defendant still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. 6. On March 26, 2009, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses. (See, Correspondence to Defendant, attached hereto and marked Exhibit "C'.) 7. Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. 8. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. WHEREFORE, Plaintiff request this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within 20 days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. ly BY y`y Edwin A. Abrah sen & Associates, P.C. Michael F. Rat ord, Esquire Heather K. W odruff, Esquire Attorney I4al Nos: 86285/207805 120 North eyser Ave Scranton, 8 504 Phone: 570-558-5510 Fax: 570-558-5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Unifund CCR Partners assignee of Palisades Collection, LLC CIVIL DIVISION Plaintiff VS. JOHN G KELL Defendant NO: 08-7553 PLAINTIFF'S BRIEF IN SUPPORT OF ITS MOTION TO COMPEL DEFENDANT'S RESPONSES TO INTERROGATORIES IN AID OF EXECUTION Plaintiff, Unifund CCR Partners assigneeof Palisades Collection, LLC, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., submits its Brief in Support of its Motion to Compel the Defendant's Responses to Interrogatories in Aid of Execution as follows: 1. STATEMENT OF FACTS Plaintiff, Unifund CCR Partners assigneeof Palisades Collection, LLC, obtained a judgment against the Defendant in regard to an outstanding, past due and defaulted credit card account. On January 07, 2009, Plaintiff served Defendant with Interrogatories in Aid of Execution of the subject judgment. (See, Interrogatories in Aid of Execution, dated January 07, 2009, attached hereto and marked Exhibit "A.') Defendant failed to respond to the Interrogatories in Aid of Execution within the time permitted by the Pennsylvania Rules of Civil Procedure. On February 27, 2009, Plaintiff sent a letter to Defendant concerning the past due responses. (See, Correspondence attached hereto and marked Exhibit "B.') Plaintiff still failed and refused to respond to the Interrogatories in Aid of Execution or respond to Plaintiffs counsel in any manner. On March 26, 2009, Plaintiffs counsel notified Defendant that he intended to present to the court the within Motion to Compel Defendant's Response to Interrogatories in Aid of Execution if Defendant continued to fail to provide the responses.(See, Correspondence to Defendant, attached hereto and marked Exhibit "C.') Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories within 30 days. More than 30 days have passed since Defendant was served with the Interrogatories in Aid of Execution. II. QUESTION PRESENTED Whether Plaintiffs Motion to Compel Defendant's responses to discovery requests should be granted when the responses are more than 30 days past due. Suggested answers: Yes III. LEGAL ARGUMENT Pursuant to the Pennsylvania Rules of Civil Procedure Defendant should have responded to the Interrogatories in Aid of Execution within thirty (30) days after service thereof. More than thirty (30) days have passed since defendant was served with the Interrogatories in Aid of Execution, however, Defendant has not answered, objected or responded in any manner to the Interrogatories or to the notice sent by Plaintiffs counsel. IV. CONCLUSION Plaintiff requests this Honorable Court to grant the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution and direct Defendant to provide full and complete response to the Interrogatories in Aid of Execution within twenty (20) days upon penalty of sanctions, and that Plaintiff be awarded attorney's fees, costs and such other relief as the court deems just and appropriate. Respectfully submitted, & Associates, P.C. VERIFICATION I, Michael F. Ratchford, Esquire, attorney for Plaintiff, Unifund CCR Partners assigneeof Palisades Collection, LLC am fully familiar with the facts set forth in the within Motion to Compel Defendent's Response to Interrogatories in Aid of Execution and am authorized to make this Verification on behalf of Plaintiff. I verify that the facts set forth in the within Motion are true and correct to the best of my knowledge, information and belief. I know that any false statements are punishable by law pursuant to 18 C.S.A. §4904. EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD HEATHER N. WOODRUFF' " ALSO A MEMBER OF Ft BAR ial THE LAW OFFICE OF EDWINA.ABRAHANSEN &ASgOCIATE8. PC JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 WWW.EAA-LAW.COM January 7, 2009 RE: Unifund CCR Partners/CITIBANK SOUTH DAKOTA NA vs. JOHN G KELL File # U08-0505 Balance: $3,894.78 Dear Sir/Madam: Enclosed please find Interrogatories for Discovery of Assets in Aid of Execution, which have been propounded in accordance with the applicable Pennsylvania Rules of Civil Procedure. Full and complete instructions concerning your duty to Answer and the penalties for failure to Answer are contained in the Interrogatories. Please read the instructions carefully. You are to note your answers on the original and return it to this office after it is properly notarized. Please be aware that under the Rules of Court, we can and will, have our attorney's fees and expenses of all discovery Proceedings and Sanction Hearings charged against you as "additional costs" for which you will be responsible. In the alternative, you may make arrangements to pay the balance owed before the thirty (30) days to Answer the Interrogatories expire. Either the balance must be paid to us or the Interrogatories answered within thirty (30) days from the receipt of this letter. This is an attempt to collect a debt and any information obtained will be used for that purpose. This is a communication from a debt collector. Edwin A. Abrahamsen & Associates, P.C. Heather K. Woodruff, Esquire 1729 PITTSTON AVENUE SCRANTON, PA 18505 (P) 570.558.5510 (F) 570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION Unifund CCR Partners, assignee of CITIBANK SOUTH DAKOTA NA Plaintiff -vs- JOHN G KELL Defendant NO.08-7553 INTERROGATORIES FOR DISCOVERY OF ASSETS IN AID OF EXECUTION DIRECTED TO JUDGMENT DEBTOR Because you have failed to pay the full amount of the Judgment previously entered against you, the Judgment-Creditor, to who you are indebted, has a right to attempt to enforce that Judgment by a Judicial Sale (Sheriffs Sale) of your assets; and has a right to inquire concerning the existence and location of those assets. Therefore, pursuant to the applicable Rules of Court, you are required to make full and complete Answers to the questions set forth in the following pages. These Answers must be made in writing, under oath, within thirty (30) days after service upon you. You are warned that, should you fail to do so, the Court may make an Order imposing punishment for Contempt of Court. Please, if you do not understand your duty to answer these questions, you should consult a lawyer. If you do not have or know a lawyer, then you should find out where you can get legal help, such as your local County Bar Association or Lawyer Reference Service. PORTIONS OF THE APPLICABLE PENNSYLVANIA RULES OF CIVIL PROCEDURE CONCERNING DISCOVERY OF ASSETS IN AID OF EXECUTION " Rule 3117. Discovery in Aid of Execution. (a) Plaintiff, at any time after judgment, before or after the issuance of a writ of execution, may, for the purpose of discovery of assets of the defendant, take the testimony of any person, including a defendant or a garnishee, upon oral examination or written interrogatories as provided by the rules relating to Depositions and Discovery...... (b) All reasonable expenses in connection with the discovery may be taxed against the defendant as costs if it is ascertained by the discovery proceedings that he has property liable to execution" (emphasis added) " Rule 4005. Written Interrogatories to a Party. (a) ......any party may serve upon any other party written interrogatories to by answered by the party served...... who shall furnish such information as is available......" of Rule 4006. Answers to Written Interrogatories by a Party. (a) (1) Answers to interrogatories shall be in writing and under oath. The answers shall be inserted in the spaces provided in the interrogatories. If there is insufficient space to answer an interrogatory, the remainder of the answer shall follow on a supplemental sheet. (b) (2) Each interrogatory shall be answered fully and completely unless objected to, in which event the reasons for the objection shall be stated in lieu of an answer.... The answering party shall file and serve a copy of the answers and objections, if any, within 30 days after the service of the interrogatories....... "Rule 4019. Sanctions. (a) (1) The court may, on motion, make an appropriate order if (i) a party fails to serve answers, sufficient answers, or objections to written interrogatories under Rule 4005.... (c) The Court, when acting under Subdivision (a) of this rule, may make...... (4) an order imposing punishment for contempt....." (emphasis added) INTERROGATORIES 1. Please state the following: (a) The full name, age and Social Security number of the person who is answering these Interrogatories. ANSWER: (b) Phone number, address and how long at this address. ANSWER: 2. REAL ESTATE: Do you have an ownership or interest in any real estate anywhere in the United States? If so, set forth a brief description thereof, included the structure and lot size and type of construction; the location, including the state, county and municipality; the volume and page number of the official record thereof; and state further whether you own is solely or together with any other person or persons and give their full names and addresses. ANSWER: (b) If any of the above properties are mortgaged, supply the names and addresses of lenders, the date and amount of the mortgage, where it is recorded, the monthly payments and the balance now due. ANSWER: 3. GOVERNMENT MUNICIPAL or CORPORATE BONDS: State whether or not you own individually or jointly any corporate or government bonds. If so, include the face amount, serial numbers and maturity date and state the present location thereof. If you own any of these Bonds jointly with any other person or persons, give their name and address. ANSWER: 4. STOCKS, SHARES or INTEREST: State whether or not you own any stocks, shares or interest in any corporation, or unincorporated association or partnership interest, limited or general and state the location thereof. Include the names and addresses of the organizations and the serial numbers of the shares or stocks. If you own any of the Stocks, Shares or Interest jointly with any other person or persons, give their name and address. ANSWER: 5. ACCOUNTS: State whether or not you maintain any checking or savings accounts. If so, state the name and location of the banks or savings and loan association or building and loan association or credit union and the branch or branches thereof, the identification numbers of those accounts, and the amount or amounts you have in each account. If you maintain any of these jointly with another person, give their name and address. State whether safety deposit. ANSWER: b. PERSONAL PROPERTY: State whether or not you own any personal property. Include a full description of all furnishings and any other items of personal property (including jewelry) with full description, value and present location. State also whether or not there are any encumbrances on that property and if so, the name and address of the encumbrance holder, the date of the encumbrances, the original amount of that encumbrance, the present balance of that encumbrance and the transaction which gave rise to the existence of the encumbrance. If you own a personal property jointly with any other person or persons, give their name and address. ANSWER: 7. MOTOR VEHICLES: State whether or not you own motor vehicles. Include a full description of such motor vehicles including color, model, title number, serial number and registration plate number. Also show the exact name or names in which the motor vehicles are registered, the present value of those motor vehicles and their present location and place of regular storage, garaging or parking. State also whether or not there are any encumbrances on those motor vehicles and if so, the name and address of the encumbrance holder, the date of the encumbrance, the original amount of that encumbrance, the present balance of the encumbrance and the transaction which gave rise to the existence of the encumbrance. ANSWER: 8. RENTAL INCOMES: State whether you are the recipient, directly or indirectly, of any income for the rental of any real or personal property; and if so, state specifically the source of payment, the person to whom such payments are made and the amount and date when those payments are received. ANSWER: Edwin A. Abrahamsen & Associates, P.C. DATED: f BY: Attorneys for Plainti AFFIDAVIT COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA SS Before me, the undersigned authority personally appeared who, being duly sworn according to law, deposes and says that the foregoing Answers to Interrogatories For Discovery of Assets in Aid of Execution are true and correct to the best of the affiant's knowledge, information and belief. SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF 20 NOTARY PUBLIC AFFIANTS SIGNATURE AFFIANTS ADDRESS TITLE OF OFFICIAL EDWIN A. ABRAHAMSEN MICHAEL F. RATCHFORD HEATHER K. WOODRUF" "ALSO MCMBER OF FL BAR JOHN G KELL 94 THE LAW OFFICE OF EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C, WWW.EAA-LAW.COM 315 MCALLISTER CHURCH RD CARLISLE PA 17015 February 27, 2009 RE: Creditor: Unifund CCR Partners Original Creditor: CITIBANK SOUTH DAKOTA NA Original Account Number: 4621200220665472 Balance Due: $4,071.07 Our File #: U08-0505 Dear JOHN G KELL: You recently received a series of Interrogatories in Aid of Execution from Edwin A. Abrahamsen & Associates, P.C. regarding a judgment that has been obtained against you by Unifund CCR Partners assignee of Palisades Collection, LLC. According to the Pennsylvania Rules of Civil Procedure, you had thirty days to provide this office with your reply to the interrogatories. To date, my office has not received a reply. Please provide an answer to these Interrogatories, or contact our office within the next 15 days, or appropriate steps may be taken with the court to compel you to answer them. This is an important matter that requires your attention. Very truly yours, 6L *ttee 6ff, E Edwin A. Abrahamsen & Associates, P.C. This is a communication from a debt collector in an attempt to collect a debt. Any information obtained will be used for that purpose. 1 729 PITTSTON AVE. • SCRANTON. PA 1 8505 0 (P) 570.558.551 0 0 (F) 570.558.551 1 CDWIN A. AORAHAMISEN MJC1449L ?, WATCHFOOD H[4067f1tM K. W000RUF ' 'ALOC wtmoce or rL PAw 94 THE LAW OFFICE OF EDWIN A. AYRANAM6EN & ASStmwtEa, P.C. Www.CAA•LAW,00M March 26, 2009 JOHN Cr KELL 315 MCALUSTER CHURCH RD CARLISLE PA 17015 Re: Unifund C:CR Partners tta4ignee of Paltmades Collecdon, LLC v. JOHN G KELL CUMBERLAND Cbun v Chi[A ction No_:CV-127-08 Our rile #:1708-0505 Dear JOHN 6 KFI.L: As you know, on lanuary 07, 2009, you ware served with Interrogatories in Aid of Execution in regard to the above-noted matter, to which you have failed to respond. As a result, please bo advised that if1 do not receive your resNnstz within ten ( 10) days of the date of this leacr, 1 intend to file a Wtion to Compel your Responses to Interrogatories in Aid of Execution in the+CUMBEW.AND Court of Common Plata. If you wish to diqcuss this issue rlr a reasonable resolution of this matter, please contact me at 570-558-5510. Mank you. tes, P.G. =atch1brd..qn T his is a communication from a debt collector in an nttempt c?crllect a debt. Any inforrnStion obtained will be used for thal purpose. 177!4 PITTSTON AVl. 4 WCRwNTCN, FA 115505 • SPI 570.559.551 ? ¦ SF? 570.558.551 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Unifund CCR Partners assignee of Palisades Collection, LLC Plaintiff VS. , JOHN G KELL , Defendant CIVIL DIVISION NO: 08-7553 CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that I caused a true and correct copy of the within Motion to Compel Defendant's Responses to Interrogatories in Aid of Execution, Brief in Support thereof, Notice of Presentation and Proposed Order via first class United States Mail, postage prepaid on the date set forth below upon the following: JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Date: P-) RLM-4-ISF CE CF THE a°R0 HONIOTA?Y 1039 OCT -2 PM 12: 53 UNIFUND CCR PARTNERS, assignee of Palisades Collection, LLC, Plaintiff V. JOHN G. KELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 08-7553 CIVIL TERM ORDER OF COURT AND NOW, this 21St day of October, 2009, upon consideration of Plaintiff s Motion To Compel Defendant's Responses to Interrogatories in Aid of Execution, a Rule is hereby issued upon Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of the date of this order. J ?Michael F. Ratchford, Esq. U Heather K. Woodruff, Esq. Edwin A. Abrahamsen & Associates, P.C. 120 North Keyser Avenue Scranton, PA 18504 Attorneys for Plaintiff John G. Kell 315 McAllister Church Road Carlisle, PA 17015 Defendant, pro Se :rc to??? o? ?l ---bely) BY THE COURT, 'i _ t ???? ?.,' ? f L ?. .i l S Unifund CCR Partners assignee of Palisades Collection, LLC VS. In the CUM Plaintiff Civil JOHN G KELL 315 MCALLISTER CHURCH RD CARLISLE PA 17015 Defendant . NO: 08- J of Common Pleas of kND County, Pennsylvania to Settle, Satisfy and Discontinue To the Prothonotary of CUMBERLAND County Please enter the above Praecipe to Settle, Satisfy and L Thank you, Michael F. Ratchford . Edwin A. Abrah en Lawyer ID # 862 5 120 N. Keyser venue Scranton PA 1 504 :squire & Associates, P.C. vania: Judgment. 0 a _n T -z7n r'n ?. to ?