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Home My WebLink About05-2910IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PALISADES COLLECTION LLC NO. OS gR 9 10 ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 PENNSYLVANIA 0,0*1 L Plaintiff VS. CIVIL ACTION - LAW DENNIS A KOHLER 14 E MAIN ST CAMP HILL PA 17011-6309 Defendant(s) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT NAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. NOTICIA Le han demandado a used en la corte. Si used quarere defensas de esas demandas expuestas en las paginas, siguientes, used tiene viente (20) dias de plazo al partir de la fecha de lademanda y la notifiation. Used debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a last demandas en corta de su persona. Sea avisado que si used no se defienda, la corte tomara medidas y psedido entrar una orden contra used sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Used puede perder dinero o sus propledades o otros derechos importantes para used. LLEVE ESTA DEMANDA A UN ABODOAGO IMMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITANCIA LEGAL. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 CVRNOT/PARET W&A FILE NO. 132661979 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. OS - //?7 ASSIGNEE OF BANK ONE o?91d 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. CIVIL ACTION - LAW DENNIS A KOHLER 14 E MAIN ST CAMP HILL PA 17011-6309 Defendant(s) COMPLAINT Now comes the Plaintiff, PALISADES COLLECTION LLC by and through its attorneys, and the law firm of Wolpoff & Abramson, L.L.P., and files this Complaint and in support avers as follows: 1. Plaintiff, PALISADES COLLECTION LLC ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 is a business entity doing business within the Commonwealth of Pennsylvania and the other states of the United States. 2. Defendant, DENNIS A KOHLER a last known address of , is an adult individual with 14 E MAIN ST CAMP HILL PA 17011-6309 COUNTY OF CUMBERLAND 3. It is averred that Defendant(s) was/were issued an open end credit card account. 4. At all relevant times material hereto, Defendant(s) has/have used said charge card for the purchase of products, goods and/or for obtaining services. CCPNRI/PARET W&A FILE NO. 132661979 5. Plaintiff provided Defendant(s) with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned credit card account to which there was no bona fide objection by Defendant(s). A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". ' 6. As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant(s) and/or any authorized users is the sum of $ 10918.62. 7. Pursuant to the applicable Pennsylvania law, any unpaid or delinquent balances on said account shall continue to bear interest at the rate of 18%. 8. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $ 5761.44. 9. Despite reasonable and repeated demands for payment, Defendant(s) has/have refused and continue to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 10. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant(s) in the amount of $ 10918.62, plus interest in the amount of $ 5761.44, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully submitted, Amy Doyl /?8 0 2 Daniel F. W lfson #20617 Bruce H. Ch rkis x/18837 Philip C. Warholic #86341 Ronald M. Abramson x/94266 Ronald S. Canter #94000 Donald P. Shiffer #89451 Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 CPNR12/PARET W&A FILE NO. 132661979 ATTORNEY VERIFICATION I hereby state that I am the attorney for the Plaintiff, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, am authorized to take this verification on behalf of said Plaintiff in this action and verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Amy F. `D'oyle x/87062 Daniel F. Wolf n //20617 Bruce H. Cherk s x/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. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 267 East Market St., York, PA 17403 (717) 846-1252 PAVERF/PARET W&A FILE NO. 132661979 18924 EXHIBIT "A" O O O N A A N N O D D O O O O N A A N N O D D 3 A r O r O A 0 A A II II II Alp O NJJ?rt p. p, W W W O NJJ-rt p.a.-i ..D\NC O I^0"QZO O"p W rtp.aAAAO"ZO OU N rtQp,OANOti7 p N Z rt J O rt `G 3 ? ] J rt `C ? l O N -I A Z -?+ N OO II II N lp II (p II N+N NN II II Ip lp II (p N+r? O<lp o D IF II n 3 m r + N+ n m Z? 3 0 a rt z a m z II II ? i-+ D N II II J II n II II II II ? - -1 rt O ?. cu 3 m o A n 3 OOUAi- IT) O A D O m ti W II 3 J II p' rti OJ+D3 aDm II W MT NN (D m 0g+ A Z II II 7 W N II Z J+ m z N II ? W0,1 F O N J Z 07 m w II II m a -Ow O J r D N a D O N N O1 N 0 O r J O w z A w m II ' O 0 Z w O1 N m -0 c 00 3 w J J Lti ? a w N IT) W 3 O1 N w Q O N N IT) N Z J [ N w O W Ip W 7 O A a A W O N < a 0O O W T N A 01 W A N D r N D O m N D O nn 00 r C r? mrt O ~ Z 0 C 03 Z Q N r? r n a nw Nm Nm z m Zw mm m W m 00 m J N W W D N Zw x U1 c' o n - YFFn J c. CC) ju j N O -f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 0502910 ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 VS. Plaintiff DENNIS A KOHLER Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), DENNIS A KOHLER and , for want of ANSWER TO COMPLAINT. ( X ) Amount due $ 10918.62 Interest $ 5761.44 Attorney's Commission $ Filing costs $ TOTAL $ 16680.06 , 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. ( X ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is tt d. DATE: Signature: --------------------------- Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (800) 830-2793 Fax: (866) 281-9028 NOW ? _? , 20W-1 JUDGMENT ENTERED A BOVE. 4rotonotary/Clerk, Civil Divisio By: ------------------ ------- Deputy PRAECJ/PANOJ W&A FILE NO. 132661979 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC No. 0502910 ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. CIVIL ACTION - LAW DENNIS A KOHLER Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND 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, DENNIS A KOHLER , above-named, is over 21 years of age; is last known to reside at 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 County of CUMBERLAND , 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. -- - - le ---- - F.-oy - Amy-- ------ 87062- --------- -Daniel-F. ------------- Wolfson--#20617--- rYL:,LYW. 7f F. ?. 'VEALTH CF PE'+` ' Philip C. Warholic #86341 / David R. Galloway #67326 . ?N " V - t f Tonilyn M. Chippie #87852 Robert N. Polas, Jr. #201259 Notarial Sea! Amy R. Wise, Notary Public Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 g Hampden Twp., Cumberland County Ronald S. Canter #94000 / Ronald M. Abramson #94266 My Commission Expires Nov. 30,2010 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff MAember, Pennsylvania Association of Notaries Attorneys in the Pr actice of Debt Col lection 4660 Trindle Road, Suite 3 00, Camp Hi ll, PA 17011 Telephone: (800) 83 0-2793 Fax: (866) 281-9028 -1 vl -!_, 200. SWORN and SUBSCRIBED to before me this ? day of Notary Public PNMAFF/PANOJ W&A FILE NO. 132661979 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC No. 0502910 ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. CIVIL ACTION - LAW DENNIS A KOHLER 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 BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 and certify that the last known address of the within Defendant(s) is: DENNIS A KOHLER 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 ---------- --------------------------- Amy F. Doy- #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (800) 830-2793 Fax: (866) 281-9028 PCRES/PANOJ W&A FILE NO. 132661979 4441 MAIN OFFICE TWO IRVINGTON CENTRE 702 KING FARM BLVD., ROCKVILLE, MD 20830 REGIONAL OFFICES 10805 JUDICIAL DR., BLDG. A-5, FAIRFAX, VA 22030 1108 E. MAIN ST., STE. 1003, RICHMOND, VA 23216 5122 GREENWICH RD., VIRGINIA BEACH, VA 23482 919 N. MARKET ST., STE. 1300, WILMINGTON, DE 19899 1 VALLEY BANK BLDG. BOX 1228, CLARKSBURG, WV 28302 2625 TOWNSGATE RD #330, WESTLAKE VILLAGE, CA 91361 46W TRINDLE ROAD, 3RD FLOOR, CAMP HILL, PA 17011 39500 HIGH POINTE BLVD., STE 250, NOM, MI 48375 300 CANAL VIEW BLVD., ROCHESTER, NY 14023 758 NORTH CARROLL AVE., SOUTH LAKE, TX 76092 180 GLASTONBURY BLVD., GLASTONBURY, CT 08033 NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS REGIONAL OFFICES LL . E31F5dfRU PHOENIX, ARIZONA ANCHORAGE, ALASKA CABOT,ARKANSAS 132661979 DENNIS A KOHLER LAW OFFICES WOLPOFF & ABRAMSON,L.L.P. Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, PA 17011 717-848-6203 OUTSIDE YORK METROPOLITAN AREA (TOLL FREE) 1-800-758-0675 FACSIMILE (717) 737-9051 PLEASE DIRECT ALL INQUIRIES TO YORK OFFICE JULY 09, 2005 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 NATIONAL COLLECTION ATTORNEY NETWORK AFFILIATED FIRM LOCATIONS CATIONS [ EGION L OFFICES OF WOLPOFF & ABRAMSON, L.L.P.] ENGL ,COLD D FARGO, NORTH DAKOTA FT. LAUDERDALE, FLORIDA CLEVELAND, OHIO NORCROSS, GEORGIA OKLAHOMA CITY, OKLAHOMA HONOLULU, HAWAII EUGENE, OREGON BOISE, IDAHO PROVIDENCE, RHODE ISLAND MERRILLVILLE, INDIANA COLUMBIA, SOUTH CAROLINA CHICAGO, ILLINOIS KNOXVILLE, TENNESSEE KANSAS CITY, KANSAS SANDY, UTAH LEXINGTON, KENTUCKY MILWAUKEE, WISCONSIN METAIRIE, LOUISIANA RAWLINS, WYOMING MINNEAPOLIS, MINNESOTA ST. LOUIS, MISSOURI GREAT FALLS, MONTANA * The National Collection OMAHA, NEBRASKA Atbrney Network Is an LAS VEGAS, NEVADA affiliation of separate law firms. MANCHESTER, NEW HAMPSHIRE CEDAR KNOLLS, NEW JERSEY W&A Hours of Operation: RALEIGH, NORTH CAROLINA 8 a.m. - 11 p.m. E.S.T. M-F IW&A File No. 132661979 Re: PALISADES COLLECTION LLC ASSIGNEE OF BANK ONE vs. DENNIS A KOHLER Docket No. 0502910 Dear DENNIS A KOHLER Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, o p o ? Amy F. Doyle #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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. / Counsel for Plaint Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Enclosure CC: DENNIS A KOHLER This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose. NOT 10D/PANOTC LTRHOt (05123105) 4442 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC ASSIGNEE OF BANK ONE 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. DENNIS A KOHLER Defendant (s) TO: DENNIS A KOHLER 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 DATE OF NOTICE: NO. 0502910 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU FAILED TO TAKE THE ACTION REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Assn. 32 S. Bedford St. Carlisle PA 17013 800-990-9108 By: C?UL?Ir Amy F. Doyle #87062 Daniel F. Wolfson #20617 Bruce H. Cherkis #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. / Counsel for Plaintiff Attorneys in the Pr actice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 IMPNOT/PANOTC W&A FILE NO. 132661979 ? ?`) C? (??' ??. m? ?' ? 1 ' W -?. ?^ ?,1 ?t ;"?, ? f -s ..? ? ? ,. . F .,? `.?. *I a 'l?'? ?? C") ?_=> ?: rf f=-?_ ?'. ?? ?: ?a to "'t:' --- ._.] -,, ,?. ?t ,? .?.!; ?,? .a a =1 '-? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 0502910 ASSIGNEE OF BANK ONE Plaintiff VS. CIVIL ACTION - LAW DENNIS A KOHLER Defendant(s) NOTICE OF JUDGMENT ( x ) Notice is hereby given that a JUDGMENT in the above-captioned matter has een entered against you in the amount of $ 16680.06 , plus interest, on (1 1 _, __, 20OL7-. ( x ) A copy of all documents filed with the Prothonotary in support of the within judgment is/are attached. Proo notary Civil Division By: ---------------------------------------- If you have any questions regarding this Notice, please contact the filing party. ---- -------------------------------------- Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Robert N. Polas, Jr. #201259 Sarah E. Ehasz #86469 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (800) 830-2793 Fax: (866) 281-9028 (This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: DENNIS A KOHLER 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 STNTC/PANOJ W&A FILE NO. 132661979 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 PALISADES COLLECTION,L.L.C. ASSIGNEE OF BANK ONE Plaintiff VS. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 0502910 DENNIS A KOHLER Defandant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of'Execution in the above-captioned matter, in the amount of $ 'to' %Q? . 6& (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against, DENNIS A KOHLER 14 E MAIN ST SHIREMANSTOWN PA 17011-6309 Defandant(s); (3) and against MEMBERS FIRST FCU located at 1000 BRYN MAWR RD CARLISLE PA 17013-1588 (4) And index this writ (A) against DENNIS A KOHLER Defandant(s) and (B) against, MEMBERS FIRST FCU Garnishee(s); ,Garnishee(s), as a lis pendens against the real property of the Defandant(s) in the name of the Garnishee(s) as follows: (Specifically describe property)***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS FIRST FCU , 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 : $ MR, A0. 069 Interest From: 06/12/2007 To Be Determined At an interest rate of 6% per year Total: $/&/ (00L)-(y_Plus costs & interest David R. Gal way #87326 ip C. Warholic - -7M Sarah E. Ehasz #86469/Robert N. Polas, Jr. M Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PABGAR/PABANK FILE # 132661979 G) OF 71"F P7 'L 1`10TARY 2099 k,,:R 20 PH 2: Ob CURIA ? ? ? *a4.60 PO ATTY 3?. c ?q W 56.50 14.00 01.50 ! 3?{. 44 - PQ A'tt? a-cc hue 60 I OVIVa59 01-to 7 e -U39 9 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2910 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Assignee of BANK ONE, Plaintiff (s) From DENNIS A KOHLER,14 E. Main Street, Shiremanstown, PA 17011-6309 (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 GARNISHEE(S) as follows: MEMBERS FIRST FCU, 1000 Bryn Mawr Rd, Carlisle, PA 17013-1588 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. 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) 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 $16,680.06 L.L. $.50 Interest from 6/12/07 at an interest rate of 6% per year -- To be Determined Atty's Comm % Atty Paid $134.49 Due Prothy $2.00 Other Costs Plaintiff Paid Date: 4/20/09 (Seal) QtGlis-R.. Lo n lary By: Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-0128 Supreme Court ID No. 86341 t IN THE COURT OF COMMON PLEAS CUMBERLAND a 'ALISADES COLLECTION, L. L. C. kSSIGNEE OF BANK ONE Plaintiff VS .DENNIS A KOHLER Defendant(s) COUNTY, PENNSYLVANIA No. 0502910 CIVIL ACTION - LAW i,kW,J -k - - - INTERROGATORIES TO GARNISHEE T0; MEMBERS FIRST FCU 1000 BRYN MAWR RD CARLISLE PA 17013-1588 RECEIVED APR 2 3 2009 PURSUANT TO RULE 3253 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 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. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate 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. SS# XXX-XX- 15114 n.mT1TT I0 AU ANA FTI.R A 11DAA1Q70 INTERROGATORIES TO GARNISHEE DEFENDANT(S) - DENNIS A KOHLER 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 an of these jointly with any other person, or persons, give their name and address. 1 132:7.4) 25, 00 0 r000M ?C 1A. DIRECT DEPOSIT ACCOUNTS: Are deposit accounts? If yes, please state the Nb ------------ - any of the accounts you have listed above direct identification numbers of those accounts. 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. NO 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. nn J? JV 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? No 5. SAFE DEPOSIT BOX: 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. - KV o T..T UTA /O AQAWr FTI-V X 1149441470 L 1 i. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendant(s) own any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full ,ralue 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 encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or ,persons, :,give names and address. 7. OTHER ASSETS: At the time you were served or at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). nn IVb 8. 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). W 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. 11-71 IUpT -1'Rke" Out f4 COPY David R. Galloway #87326 ip C. Warholic #8M Sarah E. Ehasz #8646y olas, Jr. 1 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 . ?. ?..n /n . n . •iV CT7 F # 111441070 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating f 1 to unworn falsifications to authorities, that he/she is 1 f ` u no (Name) OWA b , of fig, crs Ist Fs: ?rsi v B`!' Union T- I (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) F 1 L EU r 2CM APP 24 Ali 10: 4 CU4 ICI i'r?`? l° Sheriffs Office of Cumberland County R Thomas Kline u?cr of Lulub"'/ Edward L Schorpp '? Sheri Solicitor Jody S Smith Ronny R Anderson OFF,CE aF TF,-- St,ERWF Civil Process Sergeant Chief Deputy SHERIFF'S RETURN OF SERVICE 04/23/2009 09:30 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 04-23-09 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Dennis A. Kohler, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kimberly K. Whitaker, Branch Manager personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 04-27-09 to Dennis A. Kohler at 14 E. Main Street, Shiremanstown PA 17011. 2005-2910 Palisades Collection, LLC vs Dennis A. Kohler So Answers, R. somas Kline, Sheriff By' --' '? Deput Sherif Q c a ,J f 7. "Tr ?} rY. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, LLC ASSIGNEE OF BANK ONE Plaintiff NO. 0502910 VS. DENNIS A KOHLER Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, MEMBERS 1 ST FCU, discontinued, upon payment of your costs only. Respectfully Submitted, Dated: Vc ?2 b? Amy F. Doyle 87062 Philip C. Warholic #86341 David R. Galloway #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (866) 253-0128 MB File No. 132661979 BLED L Vii';' F nr y 2 a9,vit 1 19 i`i i 2J 7?j SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -PLED- Sheriff ' Jody S Smith Chief Deputy 2010 MAR 31 Phi 12: 32 Edward L Schorpp t Solicitor F . w a,F? Cl1MPDA`(LV; N1A NAY Palisades Collection, LLC Assignee of Bank One Case Number vs. Dennis A Kohler 2005-2910 SHERIFF'S RETURN OF SERVICE 04/23/2009 09:30 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 04-23-09 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Dennis A. Kohler, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Kimberly K. Whitaker, Branch Manager personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on 04-27-09 to Dennis A. Kohler at 14 E. Main Street, Shiremanstown PA 17011. 03/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $76.38 March 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF 7 aron R. Lantz (cj CountySuite Shenff, Teieosoft. In, 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, Assignee of BANK ONE, Plaintiff (s) From DENNIS A KOHLER, 14 E. Main Street, Shiremanstown, PA 17011-6309 (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 GARNISHEE(S) as follows: MEMBERS FIRST FCU, 1000 Bryn Mawr Rd, Carlisle, PA 17013-1588 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. 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) 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 $16,680.06 L.L. $.50 Interest from 6/12/07 at an interest rate of 6% per year -- To be Determined Atty's Comm % Atty Paid $134.49 Plaintiff Paid Date: 4/20/09 (Seal) Due Prothy $2.00 Other Costs s R. Lo o on fry By: Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: MANN BRACKEN LLP NO 05-2910 Civil CIVIL ACTION - LAW 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-0128 Supreme Court ID No. 86341 ?: ??I i ?_ ...._, ?..? ?_.