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HomeMy WebLinkAbout11-8855 FILED-OFFICE OF THE PROTHONOTARY 2012 JAN -9 PM is 00 GORDON & WEINBERG, P.C. CUMBERLAND COUNTY BY: FREDERIC I. WEINBERG, ESQUIRE PENNSYLVANIA Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2112048 FIA Card Services, N.A. VS. JOANN P NAILOR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-8855 CIVIL PRAECIPE FOR ENTRY OF JUDGKCNT BY AGREE?NT TO THE PROTHONOTARY: Enter judgment by agreement for plaintiff and against defendant(s) JOANN P NAILOR above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal Total: $3,715.15 $3,715.15 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: FIA Card Services, N.A. and that the last known address of defendant, JOANN P NAILOR, 1959 RANDALL ROAD, ENOLA PA 17025-1248. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. (?,?? 1 ?0• SD ?d cl ? abol Nb? u V1 b',- led 3. The said defendant(s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. 01 )0JI - AND NOW, this day of Ola. Judgment by agreement is entered in favor th la'?ff(s) an gainst defendant(s) at the sum of , $3,71 .15perrthe abov ertification. ProthonlQAX- GORDON & WEINBERG, P. BY: FREDERIC Y. WEIN ERG, ESQUIRE JOEL M. INK SQUIRE Attorney Plaintiff 2112048 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA Card Services, N.A. VS. JOANN P NAILOR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-8855 CIVIL NOTICE Pursuant to Pa.R.Civ.P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /X/ Judgment by Agreement $3,715.15 " Money Judgment $ L_L Judgment on Award of Arbitrators$ L_L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR JOEL M. FLINK, ESQUIRES AT THIS TELEPHONE NUMBER: 484/351-0500 ? q lob PROTHONO .6 2112048 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 FIA Card Services, N.A. 655 Papermill Road Newark, DE 19711 VS. JOANN P NAILOR 1959 RANDALL ROAD ENOLA PA 17025-1248 COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-8855 CIVIL JUDGMEM BY AGREEI4ENT AND NOW, this 3o f? day of 2011, it is hereby stipulated and agreed to by and between, JOANN P NAILOR, his/her successors and assigns and Frederic I. Weinberg, Esquire, counsel for FIA Card Services, N.A., that the Court enter a determination in the above-captioned case as follows: 1. Judgment shall be entered in the amount of Three Thousand Seven Hundred Fifteen Dollars and Fifteen Cents{$3,715.15; plus costs, in favor of FIA Card Services, N.A., and against, JOANN P his/her successors and assigns; 2. Plaintiff, FIA Card Services, N.A., will agree to accept the sum of $3,715.15 plus costs, from, JOANN P NAILOR, his/her successors and assigns. The first payment of $130.00 per month shall become due and payable on December 23, 2011, followed by 2 payments in the amount of $130.00 each, on this temporary arrangement, with future payments pending approval. 3. In the event that JOANN P NAILOR, his/her successors and assigns do not make payments as prescribed in paragraph 2, they will be considered in default and the Plaintiff, FIA Card Services, N.A., shall be allowed to exercise any and all remedies available at law. 4. The Parties to this action have authorized their respective counsel and agent to enter into this agreement on their behalf and by doing so this agreement will be binding on both that JOANN P his/her successors and assigns and, FIA Card Services, N.A., its successors and assigns. 5. As a result of this settlement, if the amount forgiven or cancelled on this debt equals or exceeds $600.00, the IRS may require Bank of America to report the amount forgiven or cancelled on a Form 1099-C. You will receive this form for the year in which the settlement is completed. If you want advice about the potential tax consequences that may result from this settlement, Bank of America recommends that you consult a tax professional of your choosing. The Bank does not make any representations about the tax consequences that this settlement may have for you or any reporting requirements that may be imposed on the Bank. Date: 162 f? ANN P NAILOR Defendant Date: _? FREDERIC W BERG, Esquire Attorney or Plaintiff I.D. #41360 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2112048 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001.E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 PROTBOND },{;r 20111114y -9 Pil 6 RL A ND PENNSY ANIUNT A FIA Card. Services, N.A. vs. JOANN P NAILOR COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-8855 CIVIL ORDER TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment entered January 9, 2012 in the above -captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P.C. BY: P005 FREDERIC JOEL M At torn WEINBERG, ESQUIRE INK, ESQUIRE for Plaintiff buALV4 510 ativa- eitf �3aa 3aSc1,o