HomeMy WebLinkAbout04-4693
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVIDIAN BANK
vs.
No. 61../ - 4(PCf3 cl;~L ~~
COMPLAINT IN CIVIL ACTION
Plaintiff
MARTHA I VICINSKI
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
JAMES C W ARMBRODT, ESQUIRE
PA I.D.#42524
WILLIAM T. MOLCZAN, ESQUIRE
PA 1.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
27 18 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(4]2) 434-7955
WWR#03427808
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROV1DIAN BANK
Plaintiff
vs.
&,J -r;.
Civil Action No. 0 '1- '-1& 9-3 '-"-
MARTHA I VICINSKI
Defendant
COMPLAINT IN CIVIL ACTION AND NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served, by
entering a written appearance personally or by an attorney and filing in writing with the court your
defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case
may proceed without you and a judgment may be entered against you by the court without further notice
for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You
may lose money or property or other rights important to you. .
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ON AGENICES THAT MAY OFFER LEGAL SERVICES TO
ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
COMPLAINT
I.
Plaintiff is a corporation with offices at P.O. Box 1244, Englewood Cliffs, NJ 07632.
.,
~.
Defendant is an adult individual residing at 424 E King Street Shippensburg, P A 17257.
3.
Defendant applied for and received a credit card issued by Plaintiff's assignor bearing the
account number 5542852300625801 .
4. Defendant made use of said credit card and has currently a balance due and owing to
Plaintiff, as of September 4, 2004, in the amount of $ 2,079.33 .
5. Defendant is in default of the terms of the cardholder Agreement having not made monthly
payments to Plaintiff thereby rendering the entire balance immediately due and payable.
6. Plaintiff avers that the Cardholder Agreement between the parties provides that Plaintiff is
entitled to the addition of financc charges at the rate of 6% per annum on the unpaid balance.
7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or
refused to pay the principal balance, finance charges or any part thereof to Plaintiff.
WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, MARTHA I
V1CINSKl individually, in the amowlt of$ 2,079.33 with continuing finance charges thereon at the rate
of 6% per annum from date of judgment plus costs.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
SHALL BE USED FOR THAT PURPOSE.
WELTMAN, WEINBERG & RBIS, CO., L.P.A.
---------:~ ."
<-~/p/f11t~
J MES C W ARMBRODT, ESQUIRE
A I.D.#42524
ILLIAM 1. MOLCZAN, ESQUIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
,/ 436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#:03427808
PAlISaS COlLECTION, LLC.
PALISADES FilE NUMBER
8953906
MARTHA I VICINSKI
NEW BALANCE
424 EKING ST
SHIPPENSBURG, PA 17257
$2,079.33
7/10/2004
I I
MINIMUM PAYMENT
IF ADDRESS AS SHOWN ABOVEJS INCORRECT. PLEASE INDICATE CHANGE BELOW.
PAYMENT DUE DATE
NAME
$2,079.33
ADDRESS _
PLEASE WRITE IN AMOUNT OF
PAYMENT ENCLOSED
$
PLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT
ACCOUNT NUMBER
CREDIT LIMIT
CREDIT AVAJABLE
PAST DUE
STATEMENT CLOSING DATE
5542852300625801
o
o
$2,079.33
7/10/2004
DATE
7/10/2004
REFERENCE NUMBER
NEW TRANSACTIONS
BALANCE DUE 7/10/2004
PALISADES COLLECTION, LLC.
DELAWARE LIMITED LIABILITY CORP.
ASSIGNEE OF PROVlDIAN BANK
P.O. BOX 1244
ENGLEWOOD CLIFFS, NJ 07632
AMOUNT
$2,079.33
PREVIOUS BALANCE
PAYMENTS AND CREDITS
NEW BALANCE
SUMMARY OF TRANSACTIONS
$2,079.33
$2,079.33
PAYMENT DUE DATE
MINIMUM PAYMENT
PROMPT CREDITlNG OF PAYMENTS; TO RECEIVE CREDIT FOR PAYMENT AS OF THE DATE OF RECEIPT. WE
MUST RECEIVE THE TOP PORTION OF THE STATEMENT AND YOUR CHECK OF MONEY ORDeR ElY 3:00 P.M, AT:
PAUSADES COLLEcnOH, Ll.C.
P.O. BOX 1244
ENGLEWOOD CUFFS, NJ 07832
PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANNER SPECIFIED AFTER THAT TIME WILL BE
CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY, THE CREOITlNG TO YOUR ACCOUNT OF
PAYMENTS REceiVED AT ANY lOCATION OTHER THEN THE ABOVE ADDRESS MAY BE DELAYED UP TO 5 DAYS
FROM DATE OF RECEJPT.
7/10/2004
$2,079.33
SEND INQUIRIES TO:
PAliSADES COLLECTION. LLC.
P.O. eox 12>14
ENGLEWOOD CLIFFS, NJ 07632
WWR . File # 3427808
.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 P A. C.S. 4904 relating
to unsworn falsifications to authorities, that he/she is
Wentworth Browne
(NAME)
Legal Operations Manager
(TITLE)
of
Palisades Collection, LLC
(COMPANY)
,plaintiffherein, that
he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint
are true and correct to the best ofhislher knowledge, information and belief.
~
Woo<worth Bm"", r
WWR#
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SHERIFF'S RETURN - REGULAR
CASE NO: 2004-04693 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VC!
~,
VICINSKI MARTHA I
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
was served upon
VICINSKI MARTHA I
the
DEFENDANT
, at 1504:00 HOURS, on the 29th day of September, 2004
at 424 EAST KING STREET
SHIPPENSBURG, PA 17257
by handing to
PATTY HUTCHISON, DAUGHTER
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
15.54
.00
10.00
.00
43.54
..~~~
R. Thomas Kline
09/30/2004
WELTMAN WEINBER
Sworn and Subscribed to before By:
me this ~ day of
(P~ a2I1v'j A.D.
(l. . t2 &J?f;~. ~ . ()~
~thonotary - r ..,--1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
No. 04-4693 CIVIL TERM
vs.
PRAECIPE FOR DEFAULT JUDGMENT
MARTHA I VICINSKI
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WW R#03427808
Judgment Amount $ 2,079.33
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
...
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
vs.
Civil Action No. 04-4693 CIVIL TERM
MARTHA I VICINSKI
Defendant
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter Judgment against the Defendant, Martha I Vicinski, above named, in the default of
an Answer, in the amount of $2,079.33 computed as follows:
Amount claimed in Complaint
Interest from date of judgment
at the legal interest rate of 6.0% per annum
$2,079.33
TOTAL
$2,079.33
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance
with PA R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.PA
By tJ~f-
William T. Molczan, Es ire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03427808
Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.PA, 2718 Koppers Building, 436 th Avenue, Pittsburgh,
PA 15219
And that the last known address of the Defendant is: 424 E King Street Shippensburg, PA 17257
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
vs.
Civil Action No. 04-4693 CIVIL TERM
MARTHA I VICINSKI
Defendant
IMPORTANT NOTICE
TO: Martha I Vicinski
424 E King Street
Shippensburg, PA 17257
Date of Notice: /0'- cX-~ ,- tJ..(
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM
THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND
YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO
A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
~:lIaf(i:fj ~
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #03427808
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according
to the Praecipe attached are not members of the Armed Forces of the United States or any other military
or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned
further states that the information is true and correct to the best of the undersigned's knowledge and
belief and upon information received from others.
WELTMAN, WEINBERG & REIS CO., L.PA
~/'//2~
By: ~
Willia T. Molczan, squire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.PA
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03427808
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IN THE COURT OF COMMON PLEAS :
,
OFCUMBERLANDCOUNTY :
.
STATE OF
PENNA.
SHAWNA S. BRENT
05-4693
No.
.
VERSUS
GEOFFREYJ.BRENT
,./
:.,
DECREE IN
DIVORCE
"
);>~;;.....
SHAWNA S. BRENT
~_, IT IS ORDERED AND
_.----~
AND NOW,
DECREED THAT
, PLAINTIFF,
AND
GEOFFREY J. BRENT
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORt> ~~ THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; Vv~
The terms of the Separation and Property Settlement Agreement dated December
11,2005 are incorporated, but not merged, into this Decreein Divorce,
--".-y
"," .. ...r "/
..,,//
By THE'COURT:. /~'. /;:-,..-
~.~~'
-~
PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, assignee
of PROVlD1AN BANK
Plaintiff
No. 04-4693
vs.
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
MARTHA L V1CINSKl
Defendant
M&T BANK,
Garnishee,
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA LD. #47437
WEL TMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh A venue
Pittsburgh, P A 15219
(412) 434-7955
WWR#03427808
.. ~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, assignee
of PROVlDIAN BANK
Plaintiff
vs.
Civil Action No. 04-4693
MARTHA L VICINSKI
Defendant
M&T BANK,
Garnishee
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
L directed to the Sheriff of Cumberland County:
2. against Martha L Vicinski, Defendant
3.
against M&T Bank, Garnishee
Less payments of
$
$
$
$
$
$
.f
2,07933 - I d..64.J.3
4.
Judgment Amount
845.00
Interest
136.13
Costs
108.04
SUBTOTAL:
1,478.50
Costs (to be added by Prothonotary):
WELTMAN, WEINBERG & REIS CO., L.P.A.
By tJjLIJtr]~
William T. Molczan, Esquire
PA LD. #47437
WELTMAN, WEINBERG & RE1S CO., L.P.A.
2718 Koppers Building
436 Seventh A venue
Pittsburgh, PAl 5219
(412) 434-7955
WWR#03427808
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-4693 Civil
CIVrL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC" ASSIGNEE OF
PROVIDIAN BANK, Plaintiff (s)
From MARTHA 1. VICINSKI, 424 E. KING ST., SHIPPENSBURG, PA 17257
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) Yon are also directed to attach the property of the defendant(s) not levied upon in the possession
of M&T BANK, 2 WEST HIGH ST., CARLISLE, PA 17013 - GARNISHEE
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
(5) 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.
Amonnt Dne $1,234.33
Interest $136.13
Atty's Corom %
Arty Paid $126.04
Plaintiff Paid
LL $.50
Due Prothy $1.00
Other Costs $108.04
Date: FEBRUARY 22, 2006
CURTIS R. LONG
(Seal)
Prothonotary 72
__By: ~~,.". Q. r07/V'L, /
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Snpreme Court ID No. 47437
;; -~ -.....
PRAECIPE FOR WRIT OF EXECUTION
P.R.C.P. 3101 to
(MONEY JUDGMENTS)
3149
STATE AUTO INSURANCE
COMPANIES
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Writ No.
Term 20
Plaintiff
NO. 2005-03889 CIVIL
Term 20~
vs
Amount due
$ 4,296.26
R. HART ENTERPRISES. INC.
5154 KEYLOCK ROAD
MECHANICSBURG PA 17055
Defendant (s)
vs
COMMERCE BANK
Interest FROM DATE OF JUDG. 112/28/05}
Atty' 5 Carom.
$ 214.81
and Costs TO BE DETERMINED$
Garnishee
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of
CUMBERLAND
County, Pennsylvania;
(2) against
R. HART ENTERPRISES, INC.
(3) and against COMMERCE BANK
Defendant (5)
Garnishee (s) ,
(4) and index this writ
(a) against R. HART ENTERPRISES, INC.
Defendant (5)
and
(b) against COMMERCE BANK
Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name at the Garnishee(s)
as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for
real estate levy)
LEVY UPON ANY PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
COMMERCE BANK, AT THE ADDRESS OF 64 ASHLAND AVENUE, CARLISLE PA 17013 (
DEFENDANT'S NAME (S)AND/OR ACCOUNT # 031301846 536000664.
ADDRESS AND GARNISH
ANY ACCOllNTS UNDER
(5) Exemption has (not) been waived.
/
Dated 02/16/06
Robert D. Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
Attorney For Plaintiff (s)
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 05-3889 Civil
CIVIL ACTION ~ LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due STATE AUTO INSURANCE COMPANIES,
Plaintiff (s)
From R. HART ENTERPRISES, INC., 5154 KEYLOCK ROAD, MECHANICSBURG, P A 17055
(I) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ANY
PERSONAL PROPERTY OF ABOVE-LISTED DEFENDANT(S) AT THE ABOVE
ADDRESS.
(2) You are also directed to attach the property of the defendant( s) not levied upon in the possession
of COMMERCE BANK, 64 ASHLAND AVENUE, CARLISLE, P A 17013 - ANY ACCOUNTS
UNDER DEFENDANT'S NAME(S) AND/OR ACCOUNT # 031301846 536000664
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 nom delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty 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 helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,296.26
Interest FROM DATE OF JUDG. (12/28/05)
Atty's Comm % $214.81
Atty Paid $165.31
Plaintiff Paid
Date: FEBRUARY 17, 2006
LL $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Prothonotary ~
~y !i?f'h.r ~ f? . ~
Deputy
REQUESTING PARTY:
Name ROBERT D. KODAK, ESQUIRE
Address: PO BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 18041
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, assignee
ofPROV1DIAN BANK
Plaintiff
vs.
No. 04-4693
.!C./"., tuefS fe
INTERROGATORIES IN ATTACHMENT
MARTHA L VICINSKI
Defendant
and
M&T BANK
Garnishee
FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA LD. #47437
WELTMAN, WEINBERG & RE1S CO., L.P.A.
27] 8 Koppers Building
436 Seventh Avenue
Pittsburgh, P A 152 I 9
(4 I 2) 434-7955
WWR#03427808
...
"
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL DIVISION
PALISADES COLLECTION, LLC, assignee
of PROV1DIAN BANK
Plaintiff
vs,
Civil Action No.: 04-4693
MARTHA L V1CINSKI
Defendant
and
M&TBANK
Garnishee
TO:
M&T Bank
2 West High Street
Carlisle, PAl 7013
Suggested Reference No.: 181-32-0859,983802790
IMPORT ANT NOTICES 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.
B. Herein, the word "defendant" means anyone or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
..
. ~
INTERROGATORIES IN ATTACHMENT
I. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason?
THIS ta A .mINT ACCOUNT l,) 'Z. "c:, Ma;;lances PrOVicJ,
M & T Bank requires written Tr: or R€!"ecf U ad
Authorization of both owners and/or Doci~nSactlons ,~, 7Postect
a Thrnovpr Ordl:l" t,i) I'elease funds.H "l-;:'fP' r,;',,,.,",.,": ",-egal
2. If the answer to Interrogatory I is in the affirmative, state the following: the amourif, ':"-':nO Fi
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location tlier~
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other wrinen
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
1t ~5>> Go "" 1
\,,-,-,,^ \t-\~\..-'d\-J:, -~ \.( L'j \.', \ ( i 'i-3' ~ .<\
~c\.s o);)t, 2'1 c, \:) '=:s
3. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant
N \~
4 . If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and
present location of each of such properties.
,~
5. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
'0\ f-"
6 . If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and
present location of each of said properties.
.------
7. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
~)\~
.
-
).-, .-. .
8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and
present location of each of such properties.
,~.
9. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
" or,
,\0 \ 'I- '
10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and
present location of each of such properties.
~---/
II. 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 his direction or otherwise discharge any claim of the defendant
against you?
\~\~
12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature,
fair market value and present location of each of such payments and properties.
\^", ,,\\ .
tK1C~WA
M& T BANK
----------
WELTMAN, WEINBERG & RBIS CO., LPA
~iIv~
By;
William t. Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., LPA
2718 Koppers Building
436 Seventh A venue
Pittsburgh, PA 15219
(412) 434-7955
WWR#03427808
"
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC. ASSIGNEE
OF PROVIDIAN BANK
Plaintiff
No. 04-4693
vs.
PRAECIPE TO SETTLE, DISCONTINUE
& END AS TO THE GARNISHEE
M&T BANK ONLY
MARTHA I. VICINSKI
Defendant
M&T BANK
Garnishee
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
WELTMAN, WEINBERG & REfS CO., 1 .PA
2718 Koppers Building
436 Seventh A venue
Pittsburgh, P A 15219
(412) 434-7955
WWR No. 0342780g
(
.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV ANIA
CIVIL DIVISION
PALISADES COLLECTION, LLC, ASSIGNEE
OF PROVIOIAN BANK
Plaintiff
V5.
Civil Action No. 04-4693
MARTHA I. VICINSKI
Defendant
M&T BANK
Garnishee
PRAECIPE TO SETTLE DISCONTINUE AND END
AS TO THE GARNISHEE, M&T BANK, ONLY
TO THE PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, M&T Bank,
only, upon the records of the Court and mark the cost paid.
WELTMAN, WEINBERG & REfS CO" L,PA
_H--~~~~71/
~~rARY PUBLIC'
::d',';
'-_...~ . .
'fl_;..,;,
...""...,.."
WWR No. OJ42780S
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y
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-04693 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
VICINSKI MARTHA I
And now SHARON LANTZ
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0010:10 Hours, on the 1st day of March
, 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
VICINSKI MARTHA I
, in the
hands, possession, or control of the within named Garnishee
M & T BANK 1 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
STEPHANIE ROUG (TELLER SUPERVISOR)
personally three copies of interogatories together with 3
true
and attested copies of the within WRIT OF EXECUTION
and made
the contents there of known to Her .
Sheriff's Costs:
Docketing
Service
Affidavi t
Surcharge
.00
.00
.00
.00
.00
.00
s~an % ~
l-" ~
.
R. Thomas Kline
Sheriff of Cumberland County
03/02/2006
By
Sworn and subscribed to before me
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
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Certified Mail
Postage
Garnishee
TOTAL
~
~
~
18.00
1.66
Advance Costs: 150.00
Sheriff's Costs 84.56
65.44
.50
1.00
4.40
Refunded to Atty on 10/05/06
30.00
20.00
9.00 I /
84.56 /~ 10 If D'
So Answers;
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Vd 'Al"nO::J uiiJ 11:J::l8WnJ
.:I.:4IB3HS 3Hl JO 3JI.:UO
'"'t)/{) ~S59te'1
R.u- i 'i '13 7D
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-4693 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC., ASSIGNEE OF
PROVIDlAN BANK, Plaintiff (s)
From MARTHA I. VICINSKI, 424 E. KING ST., SIDPPENSBURG, P A 17257
(I) 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 M&T BANK, 2 WEST HIGH ST., CARLISLE, PA 17013 - GARNISHEE
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 himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $1,234.33
Interest $136.13
Atty's Comm %
Arty Paid $126.04
Plaintiff Paid
Date: FEBRUARY 22, 2006
L.L. $.50
Due Prothy $1.00
Other Costs $108.04
CURTIS R. LONG
(Seal)
PmthonoWy ~
~: $~n~Q. -;e#-,~
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, P A 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 47437