The URL can be used to link to this page

Home My WebLink About04-5791 39 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. C>4 - S'7CJ I C l"u~ l ~€R..YvJ 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff vs. FRANK R WATTS Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), FRANK R WATTS and pursuant to the District Justice Transcript. ( X ) Amount due Less credits TOTAL $ 2205.96 $ $ 2205.96, 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. DATE: I1/~p 1 Signature: :~i/j(th#8 617 Bruce H. Cherkis 18837 Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff NOW, vA. )nl) 17 , 20~, JUDGIIEN IS ENTERED AS AB~ ~(7~f) 9. r/)~V Deputy PRAEDJ/PANOJ W&A FILE NO. 120252008 f." 'I.'" .\ ' ~.. ..... f',' -r=:::-> :J~~ ~ ::;--J . ..-.... . " \..~~ .." ": COMMONWEALTH OF PENNS\fLVANIA COUNTY OF: CUMBERLAND 09-1\-02 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS ~ALISADES COLL. LLC/PROVIDIAN NTNLI 267 E MARKET ST YORK, PA 17403 Mag D,s! No. DJ Name. Hon. I ROBERT V. MANLOVE Address 1901 :STATE 'STREET f, , CAMP'HILL"PA L ~J VS. 17011-0000 DEFENDANT: rwATTS, FRANK R 100 FRONT ST ENOLA, PA 17025-3211 NAME and ADDRESS Telephone (717) 761- 0583 I C/O WOLPOFF & ABRAMSON, LLP 267 E MARKET ST YORK, PA 17403 L Docket No.: CV- 0000354 - 04 Date Filed: 7/23/04 .J .. t1't1SJS TO NotJFY YOUTHAL;.,~-~. Judgment: 'nF:FAUT.T" ~.Ili'-JGMRNT" :PT.TF- '- " - J [iJ [i] Judgment was entered for: (Name) P1H.nUmF:S COT.T.. T.T.C/PROVTnT~N Judgment was entered against: (Name) WATT!=:, FRANK R in the amount of $ ?',?'OK;.Q6 on: (Date of Judgment) Q/?1/04 D Defendants are jointly and severally liable. D Damages will be assessed on: D This case dismissed without prejudice. (Date & Time) Amount of Judgment Judgment Costs Interest on Judgment Attorney Fees Total $ 2,099.46 $ 106.50 $ .00 $ .00 $ 2,205.96 D Amount of Judgment Subject to AttachmenU42 Pa.C.S. ~ 8127 $ D Portion of Judgment for physical dama!iler' ~r~jntl.;;9tt..t; ~f, residential lease $ ! .! . rU t I Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEALwmilN 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 DISTRICT JUSTICES, 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 DISTRICT JUSTICE. 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 DISTRICT JUSTICE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, O;;};M~::S WITH THE JUDGMENT. I ~e7Yi~t this is a tru . a o/LIj"r Date WVl? , District Justice proceedings containing the judgment. , District Justice My commission expires first Monday of January, 2006 SEAL AOPC 315-03 DATE PRINTED: 9/22/04 10:47:38 AM ""'---------- -- - //1'/7 ~ -'- \/ t~~ Sfp -~-"'-:!:,:~?'/i); / 2 J ,. - I',';" : .......... <va; I;'; ,// ~ I /. '---- ~~~</ -......,-. --" --~-- / A-, ""., j '. ~~~~ r ~ ~ ~ ~ & ~ F ~ ~ t 12 ff: -!:- (") C <: ~r; i"', ~,. I ~~ -<: 'P~ ",,- - r--> C;;:-..;l 0 :t2 -11 z ::;:J s: h1~ ~~~~ 2:3 -.J c~ ~> ~ -..... .,...:,iio. ( :~:! ( "') In 1,.0 , . ~I :~;~ :':c 31 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff vs. FRANK R WATTS Defendant(s) No. CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBEfAND ~ I, Amy F. Doyle, Esquire, 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, FRANK R WATTS , above-named, is over 21 years of age; is last known to reside at 100 FRONT ST ENOLA PA 17025-3211 County of York, 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. ~I'.' COMMONWEALTH OF PENNSYLVANIA , .. _ _Notarial Seal Dina A. Sweitzer, Notary Public City of York, York County My Commission Expires Apr. 16, 2008 SWORN and SUBSCRIBED to before me this PNMAFF/PANOJ W&A FILE NO. 120252008 4u~~~() Amy F. Doyle ~ Daniel F. Wolf n ~ 0617 Bruce H. CherklS #18837 Philip C. Warholic #86341 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff Co 11 ec t i on S day of ~OV~~ ,200L1. \)lt~.,--- Notary Public j ,., ..... C) "', C'"":). ,-.. ( C~:J ' ~' ~- .. -11 .. " , _. ~". C " -1 f ". " -,," \. , ~..::-. , , 1 "1 \.. ~';, ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC 1 No. 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff vs. CIVIL ACTION - LAW FRANK R WATTS Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 and certify that the last known address of the within Defendant(s) is: FRANK R WATTS 100 FRONT ST ENOLA PA 17025-3211 Daniel F. Wolfs Bruce H. Cherkis Philip C. Warholic WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 267 East Market Street York, PA 17403 (717) 846-1252 Counsel for Plaintiff COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dina A. Sweitzer, Notary Public City of York York County My Commission Expires Apr. 16, 2008 PCRES/PANOJ W&A FILE NO. 120252008 () 1"'-,' c' .> r) (:-: (.,') -n _1.:'-" ~" __I : " , ( r, i '" 1 0<1"';' -':.! _..,J :r-~ ..- , -., .. l .0' l " , , I -. :,:1 ...<: \.~) PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : Plaintiff vs. JUDGMENT NO. 200405791 FRANK R WATTS 100 FRONT ST ENOLA PA 17025-3211 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION (1) Directed to the Sheriff of CUMBERLAND (2) against, FRANK R WATTS 100 FRONT ST ENOLA PA 17025-3211 IN THE ABOVE MATTER. COUNTY, Pennsylvania; , Defendant (s) ; (3) and against, WACHOVIA BANK 5201 SIMPSON FERRY RD MECHANICSBURG PA 17050-351 (4) and index this wri t (a) against, FRANK R WATTS , Garnishee (s); (b) against, WACHOVIA BANK as a lis pendens against the real property of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY , Defendant(s) and , Garnishee (s), Defendant(s) in the name of the *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of WACHOVIA BANK 5201 SIMPSON FERRY RD MECHANICSBURG PA 17050-351 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 Interest from 09/21/2004 At an interest rate of 6% per year $ 2205.96 To Be Determined Dated: \"\J')\()~ Total $ 2205.96 Plus costs & interest ATTl/PAWRIT (~Q..Q, Amy F. Doyle - #87062 / Daniel F. Wolfson #20617 Bruce H. Cherkis #18837 / Philip C. Warholic #86341 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Donald P. Shiffer #89451 / Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 W&A FILE NO. 120252008 ~ ,... -r (J Sb ~ i ~~~ l ~ ~ ()- v ~ ( ~~ . . Vj () D c> ~~ -6g. w!ll::O~ ~. . . · iI{~V) ~()Vj\Y J I I :u ~ ~ [ p= \ b ...\ &;;J -I- - ~::.q-1:- - ~; 0 is II ":...n "C- =1" S.::; rilE:' ....A ... I,. ;_~ i'.) \....-' -J ~~ _c. (-:? - c...' WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5791 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC. Plaintiff (s) From FRANK R. WATTS, 100 FRONT ST., ENOLA, PA 17015-3211 (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 W ACHOVIA BANK, 5201 SIMPSON FERRY RD., MECHANICSBURG, P A 17050-351 - ALL ACCOUNTS INCLUDING, BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEN ABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attaclunent 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 $2205.96 L.L. $.50 Interest FROM 9/21/2004 AT AND INTEREST RATE OF 6% PER YEAR Ally's Comm % Ally Paid $37.25 Plaintiff Paid Date: JUNE 27, 2005 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Prothonot~ C-;J; ~: ~t1--r.( ,2. / e/?/7AJer---- Deputy . REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, P A 1701I Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 SHERIFF'S RETURN - GARNISHEE CASE NO: 2004-05791 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS WATTS FRANK R ,Sheriff or Deputy Sheriff of And now RONALD E. HOOVER Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:04 Hours, on the 29th day of June , 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT WATTS FRANK R in the hands, possession, or control of the within named Garnishee WACHOVIA BANK 604 E. HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MARY LINS (FINANCIAL SPECIALIST) 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 Affidavit Surcharge .00 .00 .00 .00 ,00 .00 So answers: ~~' . f""~'1IA"t:~ R. Thomas Kline Sheriff of Cumberland County 06/30/2005 Sworn and subscribed to before me this (. ':::: day of fl. /J c.2 00 :5 A . D . --=f17 By , ~~~1i:f /~ , ~~~J Q ~~ Pro otary SIRLIN GALLOGLY & LESSER, P.c. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee PALISADES COLLECTION, LLC : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND vs. FRANKR. WATTS : NO. 04-5791 and W ACHOVIA BANK, NA, GARNISHEE ENTRY OF APPEARANCE~ TO THE PROTHONOTARY: Kindly enter my appearance on behalf of Wachovia Bank, N.A, Garnishee, in the above-captioned matter. =~~~ Date: i~l!l.';)Q' c; C. ,-'-- ...., = = en C. c-- ,...:..::: o " ::;:J niT -,:!rn c;;C:J l..:)(L ~~:j .::::? \"~?~ t'")fTI ;::-.:, _I> :]J -< 1.0 J:i>'. ':9 c." a SIRLIN GALLOGLY & LESSER, P.C By: Jon C. Sirlin, Esquire, I.D. No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee PALISADES COLLECTION, LLC : COURT OF COMMON PLEAS : COUNr(OFCUMBERLAND vs. FRANK R WATTS and : NO. 04-5791 W ACHOVIA BANK, N.A, GARNISHEE : ATTORNEYLD.#17498 RILL OF COSTS OF GARNISHRF., WACHOVIA RANK, N.A Garnishee, Wachovia Bank, N.A, hereby bills the following costs to the fund attached and will be satisfied therefrom, as authorized by 42 Pa.CS.A Section 2503: Garnishee's fee pursuant to 42 Pa. CS,A Section 2503: Notary Charges: Entry of Appearance: Answers to Interrogatories: Order to Discontinue or Satisfy: Other: ~?OO 00 ~ 000 ~ 000 ~ 000 ~ 000 ~ 000 Costs are hereby taxed in the arnount of $ ~?OO 00 . 's;2; !:1tyOf '- )Lt..L~ PR THON ,~ BY: ,2005. 0 '"-" C") =' c,:: c? -n "" ;;:: <- --l l:', C rt-l~ ,- -vcr. rV :'JO ..:) , '_,0 _-.--'Ol -0 ,~~~?~, (' ~ ::5 rn S-~ ~? 1 :::::\ ').-:"" ", :;J -< \SJ -<: R Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL So Answers; 18.00 1.66 Advance Costs: 150.00 Sheriffs Costs 84.60 65.40 .50 1.00 3.70 Refunded to Atty on 01/18/06 30.00 20.00 .74 9.00 84.60 Sworn and Subscribed to before me c " , ,-- ~l~~t R Thomas Kline, Slieriff iln , D .J ) BU0.1I.l1 ~u.JOa 1&.. v, '-' .:::, ~ 2006 A.D. <( , " ~Flr~'? E 11 :[ c:i 8 G Nni' IDOl ':l;;iiJ.:; eg' =jilJ ""v1] . ~ c= \, ,,- 6)f..~ ~ ....'" r,- l~ 1'73;;7{ ,.fIf1] i _..,1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-5791 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC. Plaintiff (s) From FRANK R. WATTS, 100 FRONT ST., ENOLA, PA 17015-3211 (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 W ACHOVIA BANK, 5201 SIMPSON FERRY RD., MECHANICSBURG, P A 17050-351 - 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. 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) 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2205.96 L.L. $.50 Interest FROM 9/21/2004 AT AND INTEREST RATE OF 6% PER YEAR Atty's Conun % Atty Paid $37.25 Plaintiff Paid Date: JUNE 27, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonota~y' p 7." . E\y: ~a-, "- . ?/r/?/2<fA / L Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP. 4660 TRINDLE ROAD 3RO FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 71 7-303-6700 Supreme Court ID No. 87737