HomeMy WebLinkAbout04-6051
667
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
NO.
o L{;-
G OS-I
~
210 SYLVAN AVENUE
ENGLEWOOD CLIFFS, NJ 07632
Plaintiff
vs.
NANCY GROVES
Defendant(s)
PRAECIPE FOR JUDGMENT
Mr./Ms. Clerk:
Please enter Judgment in favor of Plaintiff and against Defendant(s),
NANCY GROVES and
pursuant to the District Justice Transcript.
( X )
Amount due
Less credits
TOTAL
$ 3724.79
$
$ 3724.79, 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:
10 !o~
Signature:
YJ/~n~
Amy F. oyle ' # 62
Daniel F. Wolf n 0617
Bruce H. Cherkis #18831
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,
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Prothonotary/Clerk, CiVi~.ion
By:
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Deputy
PRAEDJ/PANOJ
W&A FILE NO. 119399606
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COMMONWEALTH OF. PENNSYLVANIA
COUNTY OF: CUMBERLAND
, ,,--", \ .,/'
09-3-03
NOTICIE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
~ALISADES COLLECTION, LLC
267 E. MARKET ST.
YO~~
L ~ ~q 0 .
DEFENDAN r: NAME and ADDRESS
fGROVES, NANCY
89 SPRING GARDEN EST
CARLISLE, PA 17013
Mag, DlsI No'
'I
DJ Name' Hon
SUSAN '!.K.' DAY
Address 229 ~'~?V' STREET, BOX 167
MT. ~ SPRINGS, PA
Telephone (717) 486 - 7672 17065
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ATTORNEY FOR PLAINTIFF :
AMY F. WOLFSON, ESQ.
267 E. MARKET ST.
WOLFSON & ASSOCIATES, P.C
YORK, PA 17403
L
Docket No.: CV- 0000161- 04
Date Filed: 6/07/04
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THIS IS TO NOTIFY YOu. THAT:
- Judgment:" '
Ii} Judgment was entered for:
-DEFAtJL.T'~:N!:P PL!FF,.. -- ". - -'- '-~--" .
(Name) pJ.T.n::~nRR ~OT.T,RC'.rrToN, T.T.C'.
00 Judgment was entered against: (Name) GROVF:S, NANCY
in the amount of $
~ 724 7q on:
.
(Date of Judgment)
q/OR/04
. .
D Defendants are jointly and severally liable.
D Damages will be assessed on:
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D This case dismissed without prejudice.
f',
D Amount of Judgment Subject to
Attachment/42 Pa.C.S. S 8127 $
o Portion of Judgment for physical
damages arising out of residential
lease $
(Date & Time)
Amount of Judgment $ 3,613.41
Judgment Costs $ 111.38
Interest on Judgment $ , .00
Attorney Fees $ .00
Total $ 3,724.79
Post Judgment Credits $
Post Judgment Costs $
------------
------------
Certified Judgment Total $
- .ANY- P-AR:rlt-HAS. 'IIiE..Rl.GI:I.LTO.Ml.e.EALWJI.HJ.N.30.IlAYSAEIER.TIiE,..E.N.!BY...QE..J.uDG Nl ENLErLE.lJ.lNG.Al'lQIlkf___. . _"'0__. '__~'_'
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMEN'i/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 C'OMMON 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,
OR OTHERWISE COUPI '=s WITH THE JUDGMENT. ./'\"\'T'~';",":-' . _,
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9 f- ():/ Date
My commission expires first Monday of January, 2010
SEAL
I certify that this is a true
1~,.27-tJ,~ Date
AOPC 315-03
DATE PRINTED:
9/10/04
1:41:47 PM
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663
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
NANCY GROVES
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:
NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
//}
J(; '11Af DIu ~
Amy . Doyle ~
Daniel F. W fson #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
PCRES/PANOJ
W&A FILE NO. 119399606
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659
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
NANCY GROVES
Defendant (s)
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF YORK
The undersigned counsel, 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,
NANCY GROVES , above-named, is over 21 years of age; is last
known to reside at 89 SPRING GARDEN EST
CARLISLE PA 17013-7103
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.
."-~-" -
. Jay ,Boyl _I G/lI;;;::--
Daniel F. W 1fson ~20617
Bruce H. Cherkis #18837
Philip C. Warho1ic #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
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
qrh day of Nc:!imh(..... , 20~.
Y7I1iM~
Notary Public
PNMAFF/PANOJ
W&A FILE NO. 119399606
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655
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
NANCY GROVES
89 SPRING GARDEN EST
CARLISLEPA 17013-7103
Defendant(s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
You are her~by notified thaJr~he fo~lowiP& q~pER, DECREE or JUDGMENT has been
entered aga1nst you on /~ ~ ~~~ in accordance with the provisions
of Pa. R.C.P. 236.
the amount
motor vehicle operator's
De~~
( )
( )
( )
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 $ 3724.79, plus costs.
If not satisfied within sixty (60) days, your
license will be suspended by the Pennsylvania
of Transportation.
)
)
)
(
(
(
Verdict
Non-suit
Arbitration Award
, plus costs.
in civil action in
( )
( X )
( )
By:
C
t- .
~~h~:J
Prothonot.ary
If you have any
filing party.
this Notice, please contact the
IA
#87 #20617
Bruce H. Cherkis #1 37 / Philip C. Warholic #86341
WOLPOFF & ABRAMSON, 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. 119399606
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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
o '1-
o oS-;
Plaintiff
vs.
JUDGMENT NO. 046051
NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
Defendant (s)
To the Prothonotary: Please ..issue the Writ of Execution in the above-captioned
matter,
(1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania;
(2) against, NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
(3)
and against, COMMERCE BANK
Defendant(s);
65 ASHLAND AVE
(4)
and
(a)
CARLISLE PA 17013-2601
index this writ
against, NANCY GROVES
, Garnishee(s);
, Defendant(s) and
(b) against, COMMERCE 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)
89 SPRING GARDEN EST CARLISLE PA 17013-7103
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 COMMERCE BANK 65 ASHLAND AVE
CARLISLE PA 17013-2601
, 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 09/08/2004
At an interest rate of 6% per
C;flqj~
I I
$ 3724.79
To Be Determined
lI.TT? /PAl..lDTT
118 62 / olfson 1120617
8837 / Philip C. Warholic #86341
#94000 / Ronald M. Abramson #94266
Shiffer #89451 / Andrew C. Spears #87737
ABRAMSON, L.L.P. / Counsel for Plaintiff
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403 / (717) 846-1252
U~A PTT~ Mn l1a1oa~n~
$
3724.79
Plus costs & interest
Dated:
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 04-6051 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due PALISADES COLLECTION LLC ASSIGNEE OF
PROVIDlAN NATIONAL BANK, Plaintiff (s)
From NANCY GROVES, 89 SPRING GARDEN EST, CARLISLE, PA 17013-7103
(I) You are directed to levy upon the property of the 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 COMMERCE BANK, 65 ASHLAND AVE., CARLISLE, P A 17013-2601 - 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.
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 $3724.79
L.L. $.50
Interest FROM 918104 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Ally Paid $37.25
Plaintiff Paid
Date: MAY 24, 2005
Due Prothy $1.00
Other Costs
CURTIS R. LONG
(Seal)
Proth02 2-
__By: . 'Aa.-.t?_ . ~/(/7/'l<_(
Deputy
REQUESTING PARTY:
Name AMY DOYLE, ESQUIRE
Address: WOLPOFF & ABRAMSON
267 EAST MARKET ST.
YORK, PA 17403
Attorney for: PLAINTIFF
--~~
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
ASSIGNEE OF PROVIDIAN NATIONAL
NO. 046051
Plaintiff
vs.
CIVIL ACTION-LAW
NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
:
:
Defendant (s)
INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION
TO:
PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING
INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY
REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND
FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE
CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE
REFERENCED DEBTOR(S).
IMPORTANT NOTICES AND INSTRUCTIONS 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. The term "Defendant (s)" means the individual (s) or entity against
whom the Writ of Execution was issued.
C. "You" means the main office and all branch offices,
representatives, employees, and agents of your organization.
D. By service of the Writ of Execution upon you, all property of the
Defendant(s) subject to attachment which is in your possession, custody or
control is attached, including all property of the Defendant(s) which comes
into your possession thereafter.
E. These Interrogatories are considered to be continuing and
therefore should be modified or supplemented as you receive further or
additional information.
F.
is to be
as such,
estimate
Where exact information cannot be furnished, estimated information
supplied. When an estimate is to be used, it should be identified
and an explanation should be given as to the basis on which the
is made, and the reason the exact information cannot be furnished.
G. Where knowledge or information in possession of a party is
requested, such request includes knowledge of the party's agents,
representatives, and attorneys.
sSft 175 34 5965
ORALEX/PAWRIT
W&A FILE NO. 119399606
,
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - NANCY GROVES
89 SPRING GARDEN EST
CARLISLE PA 17013-7103
ss!1 175 34 5965
1. DEPOSITORY ACCOUNTS: At the time you were served or at any subsequent
time, state whether or not the Defendant(s) maintains any checking, savings,
lines of credit, certificate of deposit's or other depository accounts with
your institution. If so, state the identification numbers of those accounts,
and the amount or amounts the Defendant(s) has in each account. If the
Defendant(s) maintains any of these jointly with any other person, or
persons, give their name and address.
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1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have
listed above direct deposit accounts? If yes, please state the
identification numbers of those accounts.
NO
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent
time, state whether or not the Defendant(s) maintains any safe deposit box or
boxes. If so, include the identification number or other designation of the
box or boxes. Include a full description of the contents and also the amount
of cash among those contents. If the Defendant(s) maintains any of these
jointly with any other person or persons, give their full name and address.
t-jo
3. PERSONAL PROPERTY: At the time you were served or at any subsequent
time, state whether or not Defendant(s) owns any personal property that was
in your possession and/or control. If so, include a full description of all
personal property giving full value and present location. State also whether
or not there are any encumbrances or liens holders, the present balance of
the encumbrance. State where and when the encumbrances or liens was
recorded. If the Defendant(s) owns any personal property jointly with any
person or persons, give names and address.
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4. OTHER ASSETS: At the time you were served or
did you know of the existence of any other asset(s)
are not disclosed in the preceding Interrogatories.
all details concerning those asset(s).
at any subsequent time,
of the Defendant(s) which
If so, please set forth
NO
ORALE2/PAWRIT
W&A FILE NO. 119399606
.
5. PROPERTY: At the time you were served or at any subsequent time, was
there in your possession, custody, or control or in the joining possession,
custody, or control of yourself and one or more other persons any property
of any 'nature owned solely or in part by any Defendant(s)? If so, please
describe for each Defendant(s) each item of property including its value.
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6. REAL PROPERTY: At the time you were served or at any subsequent time,
did you hold legal, or equitable title to any property of any nature owned
solely or in part by the Defendant(s) or in which and Defendant(s) held or
claimed any interest? If so, describe for each Defendant(s) each item of
property including its value and the interest held by the Defendant(s).
NO
7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any
subsequent time, did you hold as a fiduciary any property in which any
Defendant(s) had an interest? If so, please describe for each Defendant(s)
the nature of the property including its value and the interest
of Defendant(s).
NO
8. TRANSFER OF PROPERTY: At any time before or after you were served, did
any Defendant(s) transfer or deliver any property to you or to any person or
place pursuant to your direction or consent. If so, for each Defendant(s)
describe the property transferred or delivered including the dates of
delivery or transfer and state the consideration paid.
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'9. FEES OUTSTANDING TO GARNISHEE: Are there any attorneys fees or
processing fees charged by you against the Defendant(s) or account(s) of the
Defendant(s) for the completion of this Answer. If yes, outline the exact
amount of any fees due and owing to the garnishee or the attorney for the
garnishee for the preparation of the swer.
$ \00 OD ~l)Q..UL4 l t1~1 /
~ h . ba.A.-l Amy . Doy' 1187062
D- -'-\ . Daniel F. olfson 1120617
Bruce H. erkis #18837
Philip C. Warholic #86341
Ronald M. Abramson #94266
Ronald S. Canter #94000
Donald P. Shiffer #89451
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P. I Counsel for Plaint'ff
Attorneys in the Practice of Debt Collection
267 East Market St., York, PA 17403
(717) 846-1252
Date:
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R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriff s Costs:
Docketing $
Poundage
Advertising
Law Library
Prothonotary
Mileage
Misc.
Surcharge
Levy
Post Pone Sale
Garnishee
Postage
TOTAL $
18.00
2.21
.50
1.00
11.10
30.00
40.00
9.00
.74
112.55
Sworn and Subscribed to before me
.
this .J.) ~ day OflikM----
2005 A.D. P~ Q 'Jrulltv ..( fk.
rot onotary 7/7
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Advance Costs:
Sheriffs Costs:
150.00
112.55
37.45
Refunded to Atty on 06/23/05
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R. Th~mas Kline, Sheriff ./
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2004-06051 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
GROVES NANCY
,Sheriff or Deputy Sheriff of
And now VALARIE WEARY
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0017:05 Hours, on the 2nd day of June
, 2005, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
, in the
GROVES NANCY
hands, possession, or control of the within named Garnishee
COMMERCE BANK 65 ASHLAND AVE
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
JENN STEIN (CUSTOMER SERVICE)
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
sop~~~~~
R. Thomas Kline
Sheriff of Cumberland County
0010010000
Sworn and subscribed to before me
this J'I €1- day 0./1..
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PALISADES COLLECTION LLC
ASSIGNEE OF PROVIDIAN NATIONAL
BANK
Plaintiff
NO. 046051
vs.
NANCY GROVES
Defendant
vs.
COMMERCE BANK
Garnishee
Garnishee:
COMMERCE BANK
65 ASHLAND AVE
CARLISLE, PA 17013-2601
PRAECIPE FOR JUDGMENT UPON ADMISSION
TO THE PROTHONOTARY:
Please enter judgment in favor of the Plaintiff and against the Garnishee, COMMERCE
BANK, in the amount of$622.77, as admitted in the answer to Interrogatories to be in the
possession of Garnishee. The amount of the judgment together with interest and cost of the
Plaintiff against the Defendant is $3724.79.
Dated: June 24, 2005
Amy F. Doyle #87062
Bruce H. Cherkis #18837
Ronald S. Canter #94000
~ld P. Shiffer #89451
Daniel F. Wolfson #20617
Philip C. Warholic #86341
Ronald M. Abramson #94266
Andrew C. Spears #87737
WOLPOFF & ABRAMSON, L.L.P.
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3'd Floor
Camp Hill, PA 17011
(717) 303.6700
Counsel for Plaintiff
W&A FILE NO. 119399606
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