HomeMy WebLinkAbout04-6048
155
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
NO. D l(~ &J<ffl
~
210 SYLVAN AVENUE
ENGLEWOOD CLIFFS, NJ 07632
Plaintiff
vs.
ROBERT K RICHTER
Defendant (s)
PRAECIPE FOR JUDGMENT
Mr./Ms. Clerk:
Please enter Judgment in favor of Plaintiff and a.gainst Defendant (s) ,
ROBERT K RICHTER and
pursuant to the District Justice Transcript.
( X )
Amount due
Less credi ts
TOTAL
$ 3810.03
$
$ 3810.03, 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 calc:ulable as a sum certain from
the complaint.
( X) Pursuant to Pa.R.C.P. 237 (Notice of PraElcipe for final judgment or
decree), I certify that a copy of this praecipe has bElen mailed to each other party
who has appeared in the action or to his/her Attorney of Record.
DATE: ~
Signature:
Amy . Doyle #87062
Daniel F. Wo Eson #20617
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, ,~ ;;L , 20 6 f ,
ision
By:
Deputy
PRAEDJ/PANOJ
W&.A FILE NO. 120277025
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151
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
No.
210 SYLVAN AVENUE
ENGLEWOOD CLIFFS, NJ 07632
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT K RICHTER
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:
ROBERT K RICHTER
62 WINTER LN
ENOLA PA 17025-2155
Amy F.~bf
Daniel F. Wolf on
Bruce H. Cherkls
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
PCRES/PANOJ
W&A FILE NO. 120277025
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC No.
210 SYLVAN AVENUE
ENGLEWOOD CLIFFS, NJ 07632
Plaintiff
vs.
CIVIL ACTION - LAW
ROBERT K RICHTER
Defendant (s)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUM~RLAND ~oet:
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,
ROBERT K RICHTER , above-named, is over 21 years of age; is last
known to reside at 62 WINTER LN
ENOLA PA 17025-2155
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.
7 e~ W~
Doyle #87062
Daniel F. Wo fson #20617
Bruce H. Cherkis #18837
Philip C. Warholic #86341
WOLPOFF & ABR~~SON, L.L.P.
Attorneys in the Practice of Debt Collection
267 East Market Street
York, PA 17403
(717) 846-1252
Counsel for Plaintiff
day of
J~bfA
, 20j)j
SWORN and SUBSCRIBED to before me this
aq
-'
PNMAFF/PANOJ
W&A FILE NO. 120277025
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
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210 SYLVAN AVENUE
ENGLEWOOD CLIFFS, NJ 07632
Plaintiff
VS.
NO.
ROBERT K RICHTER
CIVIL ACTION - LAW
62 WINTER LN
ENOLA PA 17025-2155
Defendant(s)
TO: ROBERT K RICHTER
NOTICE OF ORDER, DECREE OR JUDGMENT
62 WINTER LN
ENOLA PA 17025-2155
You are hereby notified _,~ha~ ~he_f,,~iIOW~g~O~~R, DECREE or JUDGMENT has been
entered against you on' ~ _ ~ d-O(j't- in a.ccordance wi th the provisions
of Pa. R.C.P. 236.
If you have any questions regarding this Notice, please contact the
filing party.
(
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( X )
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Decree Nisi in Equity
Final Decree in Equity
Judgment of ( ) Confession
( ) Default
( ) Non-pros
Judgment is in the amount of $
District Justice transcript of judgment
of $ 3810.03, plus costs.
If not satisfied within sixty (60) days, your motor vehicle
license will be suspended by the Pennsylvania Department
of Transportation. ~/ 1
By: l!tAA.)~ I
Prothonotary
(
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)
Verdict
Non-suit
Arbitration Award
, plus costs.
in civil action in
the amount
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operator's
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Daniel F. Wolfson #20617
is #18837 / Philip C. Warholic #86341
WOLPOFF & ABR SON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
267 East Market Street, York, PA 17403
(717) 846-1252
(This Notice is given in accordance with Pa. R.C.P. 236.)
DJNTC/PANOJ W&A FILE NO. 120277025
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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. 046048
:
ROBERT K RICHTER
62 WINTER LN
ENOLA PA 17025-2155
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
Defendant (s)
To the Prothonotary:
matter,
(1) Directed
(2) against,
Please reissue the Writ of Execution in the above-captioned
to the Sheriff of CUMBERLAND
ROBERT K RICHTER
62 WINTER LN
ENOLA PA 17025-2155
COUNTY, Pennsylvania;
(3)
and against, M & T BANK
, Defendant (s) ;
344 SlOTH ST
(4)
and
(a)
LEMOYNE PA 17043-1707
index thi s wri t
against, ROBERT K RICHTER
, Garnishee (s);
, Defendant(s) and
(b) against, M & T BANK , Garnishee(s),
as a lis pendens against the real property of the Defendant(s) in the name of the
Garnishee(s) as follows: (Specifically describe property)
62 WINTER LN ENOLA PA 17025-2155
All personal property of any nature located within the household or immediate
vicinity of the Defendant(s) address and all other personal property within the
dominion and control of the Defendant(s) wherever it is located shall be subject to
the levy.
ALSO: You are directed to attach the property of the Defendant(s) not levied upon in
the possession of M & T BANK 344 SlOTH ST
LEMOYNE PA 17043-1707
, Garni shee (s)
All accounts including 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 09/02/2004
At an interest rate of 6% per year
Dated: ~
$ 3810.03
To Be Determined
Total $
3810.03
Plus costs & interest
00{ ^-
Amy F. Doyle U87062 / Daniel F. Wolfson #20617
Bruce H. Cherkis #18837 / Philip C. Warholic #86341
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WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, CamD Hill. PA 17011 I (717) .n'_,,~nn
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION LLC, Plaintiff (s)
NO 04-6048 Civil
CIVIL ACTION - LAW
From ROBERT K. RICHTER, 62 WINTER LN, ENOLA, P A 17025-2155
(I) You are directed to levy upon the property oflhe defendant (s)and to sell ALL PERSONAL
PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE
VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL
PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S)
WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of M & T BANK, 344 S 10TH ST., LEMOYEN, PA 17043-1707 - 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 him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $3810.03
L.L. $.50
Interest FROM 9/2/04 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comrn %
Atty Paid $37.25
Plaintiff Paid
Date: SEPTEMBER 29, 2005
Due Prothy $1.00
Other Costs
(Seal)
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prothonotary..~7
By:
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON
4660 TRINDLE ROAD
3RD FLOOR
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court 10 No. 87737
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
PALISADES COLLECTION LLC
ASSIGNEE OF PROVIDIAN NATIONAL BANK
210 SYLAN AVENUE
ENGLEWOOD CLIFFS. NJ 07632
Plaintiff
NO. 046048
vs.
CIVIL ACTION - LAW
ROBERT K RICHTER
62 WINTER LN
ENOLA PA 17025-2155
Defendant (s)
PRAECIPE TO DISMISS WRIT OF EXECUTION
To the Prothonotary:
Please dismiss the Writ of Execution which has been filed in the above-referenced matter due to
defendant has filed bankruptcy case #05-05327 on September 26, 2005.
Dated: Mor
Respectfully Submitted,
G--t
--
Amy F. Doyle, Esquire ID No. 87062
Daniel F. Wolfson, Esquire ID No. 20617
Philip C. Warholic, Esquire ID No. 86341
Donald P. Shiffer, III. Esquire ID No. 89451
Andrew C. Spears, Esquire ID No. 87737
WOLPOFF & ABRAMSON, LLP
Attorneys in the Practice of Debt Collection
4660 Trindle Rd., 3'd Floor
Camp Hill, PA 17011
(717) 303-6700
W&A File No. 120277025
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriffs Costs:
Docketing $
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Garnishee
Postage
TOT AL $
Advance Costs:
Sheriffs Costs:
150.00
107.68
42.32
18.00
2.12
.50
1.00
16.32
Refunded to Atty on 10/07/05
40.00
20.00
9.00
.74
107.68
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R. Thomas Kline, st'riff' (
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Sworn and Subscribed to before me
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6048 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION LLC, Plaintiff (s)
From ROBERT K. RICHTER, 62 WINTER LN, ENOLA, PA 17025-2155
(I) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL
PROPERTY OF ANY NATURE LOCATED WITIDN THE HOUSEHOLD OR IMMEDIATE
VICINITY OF THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL
PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S)
WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of M & T BANK, 344 S 10TH ST., LEMOYEN, PA 17043-1707 - 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 orfor 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 helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $3810.03
L.L. $.50
Interest FROM 9/2/04 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $37.25
Plaintiff Paid
Due Prothy $1.00
Other Costs
Date: SEPTEMBER 29, 2005
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By: ' fI':-...:/-
(Seal)
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON
4660 TRINDLE ROAD
3RD FLOOR
CAMP HILL, P A I70n
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87737
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-06048 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
RICHTER ROBERT K
And now CPL. TREVOR KENT
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0016:00 Hours, on the 5th day of October ,2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
RICHTER ROBERT K
, in the
hands, possession, or control of the within named Garnishee
M & T BANK 344 S. 10TH ST
LEMOYNE, PA 17043
Cumberland County, Pennsylvania, by handing to
KEN LOUCKS (MANAGER)
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 His .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So ans;,,~ ~
~~.-l"'~ _ -&<.,
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
10/07/2005
Byd,,~ Y
Deputy Sheriff
eV Iir'
this Ii) - day of l\ v:;;::~
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~honota . '
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
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TO THE PROTHONOTARY OF THE SAID COURT:
) Confessed Judgment
( ) Other
File No. L9:xJ5" - c, ol{g
Amount Due :J8'7tj. 20
(IVIL
Interest
Atty's Comm
Costs
C oL<,.J' /fL r' A.t..r '--
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of ~ hi "J County,
for debt, interest and costs, upon the following described properlY of the defen ant(s)
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PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of County, for debt. interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
o (Indicate) Index this writ against the garnishee(s) as a lis pe~gainst real estate of the
<- efendant(s) described in the attached exhibit. ~ - _
Date s;: "l-c 0 S Signature: ~ /
Print Name: S'f1=.'i'ltJ M. L-'i::',v'S
Address:tD D 0)1... IoCr, I ~_
0BC'pA- 1)lo<;;-oCc(~
Attorney for:
Telephone:
() IJ) 32,9- (./}9.s
Supreme Court ID No.:
(over)
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WRIT OF EXECUTION andlor A TT ACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N005-6048 Civil
CIVIL ACTION - LA W
TO THE SHERIFF OF DAUPHIN COUNTY:
To satisfy the debt, interest and costs due Steven M. and Susan M. Long Plaintiff (s)
From JOHN AND CAROL HALL, 27O-C ARLINGTON AVENUE, HARRISBURG P A 17109
THE BROOK APT COMPLEX NEXT TO COLONIAL PARK.
(I) You are directed to levy upon the property of the defendant (s)and to sell Any and all personal
property and all vehicles, boats, plane everything.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(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 tbat helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due$5874.28
L.L.
Interest
Atty's Corom
%
Due Prothy $1.00
Other Costs
Ally Paid
Plaintiff Paid $34.25
Date: December 5, 2005
I
,
,
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name Stephen M. Long
Address: P.O. Box 10614
Harrisburg PA 17105-0614
Attorney for: Plaintiff
Telephone: 717-329-6795
Supreme Court ID No.
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