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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 p ~ ~~~ fl\~1 Cr; !Ii. }/t:.; ;:] .b-c, ~ ':';> $ - "'-- ~ <:::.:i ..r:- fi? ("'j I I'\) fi? S!...... (;1,::d :"'8gO'l o :::-f .7:: ::,-. O~~I i!5f;1 ,);! .'J::i -.::: 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 Q ~;.; "-::-:;-i""i; r, i-; ::.~~ .+;;;~. .- ,. f'-.,) c.;..) 'f,:.:> .J..- o '-'-1 <.-.:) o -n :-:1 .L,., lllf= -niT) '~.-} '? r'Jt~ ['...>> I t1 "~ I r---,) -'j'l r--., 147 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 " (j f--,) 0 C-...::J- (' C,',:::l -n "L.- r:::l -4 T Pi r.1 ;:g c; -r,rn (," . I '-7 f',) Cl ~ l' ~ -n -,1 _..I.:',.. h rn r,,) ..,.... -' :-=:_J .t,;- -..::. 143 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC . --: . ~E'- \ 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. ( ( ( ( ) ( X ) ( ) ) ) 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 ( ( ( ) ) ) Verdict Non-suit Arbitration Award , plus costs. in civil action in the amount ) operator's r 'tAb 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 -J '1-" .('> -.J ..j -J -- ~ \-; .,. ~~ o ,'- ~ c.:,.,) c:;;.-:> ....- ;0 o -n c> --1 ( r.::J :],:-n ~ r1 ftl i-:-: \ ' ('", -n rn '__ : ~~?i ~i ~~ ~ ..r~' .. ---- -S) , ~ '"\ \ c::.., "-, 34173 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 ~~~:~: :: ~~7i;:r ~~~~~~ j ~/~:i}~.;~on ~~j;~~ 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 'G t, ,-1 Q --r 1- I~ b -- ..C; . IS"- ~ ..() - ~ - ...z::: ~0 6 ~ l l \1 (/\ l -'4 ~ o 8 C> (' 0 r \ ~ w ~ ~ -IC.. - - - - V1. ..0 . ~ . Vl <0 }-> () ~ ~ -J - 0 r - 't -:p tA:Jj::: ~r -- ~ Q. {"} It;; ~-\ s;" u" :r:, -;g en 1\ l:-n <-0 -0 \...-, -,'")'-...::' i'") ('j ()_ UJ j';~, ~~ C{; ?i .r <J1 <~-' " -------- 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) (!~~ 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 0 "" 0 c:) c:: <.::';.] -'1'1 eJ' -7 f'?i -I''', cc> C') cr, ,( 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 ~ ~ -. So Answers; r"~.~t R. Thomas Kline, st'riff' ( BycnD-wiifu ~ak {" o -t'. ~ Sworn and Subscribed to before me ,r' ~." J LS :b 'J Of: [::J~ \uOI (<::,""'-. I::::.:.>~ ",Pi- 'i.., <'.._,V /,1 ~"'''''' ~;i) u'J jSV UL ,;fs'c.o It.:"" It... 'i' f'f,}- .~\ 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 (!.~) Uk':. ~'1 prothon~,"'" ,7 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:;;::~ "00" ~ ~Lh ~honota . ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: L (i".J q 5-;z= fl /kv ;11, f , S;c\s.<rJ ~: \-\ -I\- LL 1 vs. I ~ ) L,~lfJ,v' ( C"f/l..oL- 2- 7 0 ,- C fT UI 'II (,70 t.J frv b I-IITIZ-,IZ../ 5 /~iJ!2- c: f?A n / (/ '7 I . 711 G: t5/2-c),'IL. If/'/" c:7..>~ I".c "''>< U>XT'fV 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) ,/ltv'ij /f/VLJ Ar/ L- JJL7Z-SN '/~/'e,'tJ'~-/ /!/1/J/ /9t..-/.--- (/Er/rcLt:.-S- bvk,? '/~~ 67/t:7~c; / 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) , "'t -._.f ...... '"'" '- ~ ~ ---- '.."_J \ --1..1 \-'\ --e- ~ D "0 \t.) ~) <:::J G') '::.:.. '0/' J; C) ~ "=', --"0 ~ -;; " .~ ;::;> '" r--- " " ,~ '0 0 ~. ;:.> - ........ ~ 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. , ~:':~ ~J1L.7Ii. ;fit'. - f'~I:!:' ," ~.~\' .~:J:::i&,. 1/ k1L..:~ - /"" j.. ~ t. ._...._~_ .~~~ ,'''''1'"1''''-. . ,~