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Home My WebLink About05-1608 1021 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. uS - llooP Co~Lc,~ 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff vs. ROGER liARTIN Defendant (s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter ROGER liARTIN pursuant to the District Judgment in favor of Plaintiff and Justice Transcript. and against D~fendant(S)' , , I I \ ( X ) Amount due Less credits TOTAL $ $ $ 2701.16 , plus interes and costs 2701.16 ( X) I certify that the foregoing assessment of damage amounts alleged to be due in the complaint and is calculable a the complaint. I ( X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe forjfina1 judgment or decree), I certify that a copy of this praecipe has been mai1e to each other who has appeared in the action or to his/her Attorney of Recor . ! is for specified a sum certain from party NOW, ("rGJarl-.. ;;}L( , 2~, Amy F. Doy1 e 7062 Daniel F. Wo1 son #20617 Bruce H. Cherkis #18837 Philip C. Warholic I {18634l Ronald M. Abramson I 1194266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L. .P. Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 , Counsel for Plaintiff ! JUDGMEN IS ENTERED A ABOV~. DATE: 3~1 /6> I / Signature: PRAEDJ/PANOJ W&A FILE NO. 125542403 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUKBBRLAlQ) 09-2-01 NOTICE OF JUDGMENTITRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRr:SS IpALI:SADBS COLLBCTI:OJII LLC 267 B. JI}lV1r1l!T ST C/O WOLPOPP & ABRAHSOJII [!OU:, PA 17403 -. Mag Dist. No' MDJ Name: Hon. PAULA P. COP~lUU. Add"", 1 COURTHOUSB SQUAD CARLI:SLB, PA ...J VS. T",phooo (717) 240-6~64 17013-0000 DEFENDANT: IDaTI:JII, ROOD' 225 S. BAlIIOV:B ST APT/8TB A CARLISLB PA 13 L ~5Sl.{IJL-jo -04 NAME and ADDRESS I PALI:SADBS COLLBCTI:OJII LLC 267 B. KaV1r1l!T ST C/O WOLPOPP & ABRAHSOJII YOU:, PA 17403 12/2 /04 ...J 1& THIS IS TO NOTIFY YOU THAT: Judgment: -" . ~ + '., li] Judgment was entered for: (Name) POll,-,.a TRT:J:I!'I!' . ,'. .... 'I PlIT.TAlIn1l!A I"OT.T.1I!1"'I'TON' ~.T.I" . li] Judgment was entered against: (Name) UlIV'I'Tllr, Roa.ll in the amount of $ '2 'JR1 16 on: (Date of Judgment) '2/R'J/Rr;. . o Defendants are jointly and severally iiable. o Damages will be assessed on: (0 ate & Time) Amount of J dgment $ 2.618.16 Judgment C sts $ 83.00 Interest on J dgment $ .00 Attorney Fe s $ .00 Total , $ 2.701.16 I Post JUdgm;nt Credits $ Post Judgm nt Costs $ \ ------------ ------------ Certified Judgment Total $ o ThIs case dismissed without prejudice. O Amount of Judgment Subject to Attachment/42 Pa.C.S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ C, "___ ._ ANY ~W~HT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APP . lfabNOTARY/CLERK OF THE COURT d.. l.iOMMUN ~Lt:A:S, l;lvlc'urvrSTcpN. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTfTRANSCRIPT FORM WITH YOUR NOTICE' F APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL 01 TRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, A FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAYBE ISSUED BY T E MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTE IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JU MENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. 2/7/05 Date , Magis erial District Judge I certify that this is a true an 2/7/05 rocee containln~ the judgment. , , Magisterial DIstrict Judg'e ! Date My commission expires first Monday of January, 2006 , ! SEAL AOPC 315.05 DATB PRI:JlTBD: 2/08/05 8:07:26 AM ,------------ ' o 1~,:.,CQ, JiW' !iill :,; ," 9 'if"''!; II t '" 11 ,~.,j((.. 1 1 .-.J.: ,,-- .'. ,. "'\ <{ 1018 , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. ROGER MARTIN , CIVIL ACTION - L1W 225 S HANOVER ST # A CARLISLE PA 17013-3914 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: ROGER MARTIN 225 S HANOVER ST # A CARLISLE PA 17013-3914 ) ) ) DECREE or JU~MENT in accordanCr with , I , I I I , has been the provisions You are hereby notified that the following ORDER, entered against you on /Y1.:;;J./l r J... ;:;'1-/ ~ 6/) ( of Pa. R.C.P. 236. ( ( ( ( ( ) ( X ) ( Decree Nisi in Equity Final Decree in Equity Judgment of ( ) Confession ( ) Defaul t ( ) Non-pros Judgment is in the amount of $ District Justice transcript of judgment of $ 2701.16, plus costs. If not satisfied within sixty (60) days, your license will be suspended by the Pennsylvania of Transportation. ( ( ( ) ) ) Verdict Non-suit Arbitrat , plus co in civil on Award ts. ction in the amount mot r vehicle operator's Dep rtment ) By: If you have filing party. the Daniel F. W #20617 Philip C. W #86341 Ronald M. A ramson #94266 Donald P. S iffer #89451 WOLPOFF & ABRAMSON, L.L.P. / Counselor Plaintiff Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 / (717) 846-1252 accordance with Pa. R.C.P. 236.) Amy F. Doyl Bruce H. C Ronald S. DJNTC/PANOJ (This Notice is given in W&A FILE NO. 125542403 1019 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC No. 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaint i ff vs. CIVIL ACTION - Lt \ ROGER MARTIN Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK The undersigned counsel, being duly sworn according to la that I am the Attorney for the Plaintiff in the above-captione the best of my knowledge, information and belief Defendant, ROGER MARTIN , above-named, is over 21 year known to reside at 225 S HANOVER ST # A CARLISLE PA 17013-3914 , depose and say matter, and that to of age; is last County of CUMBERLAND the United States or Servicemembers Civil I , Pennsylvania; is not in tje military service of its Allies, or otherwise within the provi ions of the Relief Act and its Amendment. I ---------- COMMONWEALTH OF PENNSYLVANIA Notarial Seal Dim A. Sweitzer, Notary Public Citv of York. York County My Commission Expires ApT 16, 2008 Amy . Doy 1187062 Daniel F. Ifson /120617 Bruce H. erkis #18837 Philip C. Warholic #86341 Ronald M. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer, III #89451 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practi e of Debt Collection 267 East Market St., Yo k, PA 17403 (717) 846-1252 I o nse~a~o:f~tf~~ ,20~ I ! SWORN and SUBSCRIBED to before me this PNMAFF/PANOJ W&A FILE NO. 125542403 1020 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND PALISADES COLLECTION LLC 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff vs. ROGER MARTIN Defendant (s) COUNTY, PENNSYLVANIA No. i CIVIL ACTION - LAf I I i ! CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 I I wi thin Defendant!(s) I I I I I I and certify that the last known address of the ROGER MARTIN 225 S HANOVER ST # A CARLISLE PA 17013-3914 PCRES/PANOJ W&A FILE NO. 125542403 is: Amy F. Doyle 1/87062 Daniel F. W fson #20617 Bruce H. CHerkis 1#18837 Philip C. Warholic #86341 Ronald M. Abramson !#94266 Ronald S. Canter 1/194000 Donald P. Shiffer, III 1#89451 WOLPOFF & ABRAMSON, L.L.IP. Attorneys in the Practi~e of Debt Collection 267 East Market St., Yo~k, PA 17403 (717) 846-1252 , Counsel for Plaintiff ~ ~ '6S.- i 1. ~ ~ p ....., c:'~ 0 c-, '.;;-) ...." CJl F ....... ~ ::rJ (l- V :-v rfi:TI ,- ~ "" "r;f'l --() ~ :1,)0 ~ ~- ,~,.~ r y ~ --':() !!( f1- --;-; :- -n .' --,- 'e2(") r t2 , ~ in c) ~-' .. -=-! . C.d :0 -, w --< PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) PoR.C.P. 3101 to 3149 PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaint i ff vs. JUDGMENT NO. 051608 ROGER MARTIN 225 S HANOVER ST # A CARLISLE PA 17013-3914 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, ROGER MARTIN 225 S HANOVER ST # A CARLISLE PA 17013-3914 IN THE ABOVE MATTER. COUNTY, Pennsylvania; (3) and against, WAYPOINT BANK 1160 WALNUT BOTTOM RD CARLISLE PA 17013-9146 (4) and index this writ (a) against, ROGER MARTIN , Defendant (s); , Garnishee (s) ; (b) against, WAYPOINT BANK as a lis pendens against the real property of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY , Defendant(s) and , Garni shee (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 WAYPOINT BANK 1160 WALNUT BOTTOM RD CARLISLE PA 17013-9146 Garni shee (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 02/07/2005 At an interest rate of 6% per year '1ljql~ $ 2701.16 To Be Determined Total $ 2701016 Plus costs & interest Dated: (lH ~ Amy Fo Doyle #87062 1 Daniel F. Wolfson #20617 Bruce H. Cherkis #18837 / Philip C. Warho1ic #86341 Ronald So Canter #94000 / Ronald M. Abramson #94266 Donald P. Shiffer 1189451 / Andrew C. Spears 1187737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trind1e Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 W&A FILE NO. 125542403 ATT1!PAWRIT s ~- ;- .-I-- -'<l ;/Q-;- V) () C' \'). 'j-(} p ~1- -0 -tr-) ~ ...0 ...c~ --~ ~ ~ (Y:J % ~ '()- (,. ~ i ifl- iA.. W (\, ...a u; ....t X-J - ~r~8 \ l I -cJ -- ::2\L '+ , ~~& ,- ~ 0 () ,:;;:~ "11 ,': "-" -.-\ Ci? :J:;-n ...'-n rt'r ~ -~Jrr], N ~b \y '-.D .~,),C> ";"..,.-, -, :",c".'.;{2. ~~- ....' -.... f;;,rn q:; 5il ;:;' ~ N - .----- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 05-1608 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC., Plaintiff (s) From ROGER MARTIN, 225 S. HANOVER ST. # A, CARLISLE, P A 17013-3914 (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 W A YPOINT BANK, 1160 WALNUT BOTTOM RD., CARLISLE, P A 17013-9146 - 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 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2701.16 L.L. $.50 Interest FROM 7/22/2004 AT AN INTEREST RATE OF 6% PER YEAR Arty's Comm % Arty Paid $37.25 Plaintiff Paid Date: SEPTEMBER 29, 2005 Due Prothy $LOO Other Costs 1. " (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-01608 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS MARTIN ROGER And now J.M. ICKES ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:45 Hours, on the 3rd day of October 2005, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , in the MARTIN ROGER hands, possession, or control of the within named Garnishee WAYPOINT BANK 1160 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, pennsylvania, by handing to DENISE WESTOVER (ASST. 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 Her . Sheriff's Costs: Docketing Service Affidavit Surcharge .00 .00 .00 .00 .00 .00 So ~4f!u R. Thomas Kline Sheriff of Cumberland County 10/04/2004 Sworn and subscribed to before me this ~ day of ~'1--f{)...u,. '~:l~d By -J 111.AioJ j).jJ.~ Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NO. 051608 Plaintiff vs. CIVIL ACTION-LAW ROGER MARTIN 225 S HANOVER ST # A CARLISLE PA 17013-3914 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 CREDITORtS 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. SSf! 173 56 5173 ORALEX/P AWR IT W&A FILE NO. 125542403 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - ROGER MARTIN 225 S HANOVER ST g A CARLISLE PA 17013-3914 ssg 173 56 5173 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. Yes-See Attached 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. Any direct deposit agreements for automated deposits are between our customer and the originator of these deposits. Sovereign Bank is not a party. 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. No 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. No 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. 125542403 5. PROPERTY: At the time you were served or at any subsequent time, was there 10 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. No 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 i tern 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. No 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 Answer. See Attached WtQ Amy F. Doyle 1187062 Daniel F. Wolfson #20617 Bruce H. Cherkis #18837 Philip C. Warholic #86341 Ronald H. Abramson #94266 Ronald S. Canter #94000 Donald P. Shiffer #89451 Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaint'ff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 170 1 (717) 303-6700 Date: ~jlq/O\- ORALE3/PAWRIT W&A FILE NO. 125542403 ANSWER TO INTERROGATORIES Account # 289-1050118 Balance: $0.00 After deducting $13.05 of our customary $75.00 Legal Processing Fee. Account Holder: Roger W. Martin 512 S. West Street Carlisle, PA 17013-3856 VERIFICATION I, Timothy J. Cooney, OAG Team Leader of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank 1 By: Timothy J. Cooney GAG Team Leader ....', t:::::',.J C:::::::";' c..r> C") c) o -n "-;4 rVi 1....:::3 G.) = +~. il. o~- )(.09 ~ /-<- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA INRE: Palisades Collection, LLc vs. Roger Martin CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Andrew C. Spears, Esquire Wolpoff & Abramson 4660 Trindle Road, 3rd Floor Camp Hill, P A 170 II Service by certified mail addressed as follows: Roger W. Martin 512 S. West Street Carlisle, PA 17013-3856 Signature 0 Per on Filing Timothy J. Cooney, OAG Team Leader Sovereign Bank MAl MB3-02-1O 2 Morrissey Boulevard Boston, MA 02125 October 17, 2005 ~, cz> c.:~':'l ''::''1'1 CJ (''') () -n l.:,) C~ c-, ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 051608 vs. CIVIL ACTION - LAW ROGER MARTIN Defendant PRAECIPE TO DISMISS WRIT OF EXECUTION To the Prothonotary: Please dismiss the Writ of Execution which has been filed in the above-referenced matter. Dated: II It /O( I ( Respectfully Submitted, LJ~U Amy F. Doyle #87 2 Daniel F.. W?!1'~ql1 0617 .If .V'...!'(frittf16lic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3" Floor Camp Hill, PA 17011 (717) 303.6700 W&A File No. 125542403 (jl ..'., v:> ,-> <'7':',:-1 '--;.1 ~:r.' cr. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriffs Costs: Advance Costs: Sheriff s Costs: 150.00 137.26 $ 12.74 Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Certified Mail Post Pone Sale Garnishee 9.00 Postage .74 TOTAL $ 137.26 Sworn and Subscribed to before me 18.00 54.02 .50 LOO 4.00 30,00 20.00 Refunded to Atty on 11117/05 so~ r ~~ ~. ~homas Kline, S'te::- / ~ 0-uJ-'L- ~ubd-V By Claudia A. Brewbaker \.'l "', , "- " \) '" 2005 A.D. ,~ 'i,> 0"'~ ,/ ''>(~''~..f' />'m'" " ":/f)1 .' ~:; 8'; :b u [. r. ~ S!~LL ", /y '1/ I.~ cr~{l DtJ3 & 1l1':,"/? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC., Plaintiff (s) NO 05-1608 Civil CIVIL ACTION - LAW From ROGER MARTIN, 225 S. HANOVER ST. # A, CARLISLE, PA 17013-3914 (1 ) You are directed to levy upon the propertY of the defendant (.)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of WAYPOINT BANK, 1160 WALNUT BOTTOM RD., CARLISLE, PA 17013.9146 - 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 ofthe 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2701.16 L. L. $.50 Interest FROM 7/22/2004 AT AN INTEREST RATE OF 6% PER YEAR Ally's Comrn Atty Paid $37.25 Plaintiff Paid Date: SEPTEMBER 29, 2005 % Due Prothy $1.00 Other Costs (Seal) (:~,>'t.r~Lfi Prothonotary' 1.,/ By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON 4660 TRlNDLE ROAD 3RD FLOOR CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 86341