The URL can be used to link to this page

Home My WebLink About05-5240343 IN THE COURT OF COMMON PLEAS OF &(nWV Cq(k COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION NO. US - 5?24'D l [c??(??/??? P.O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff VS. LISA A BALKO Defendant(s) Mr./Ms. Clerk: PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), LISA A BALKO and , pursuant to the District Justice Transcript. ( X ) Amount due $ 1460.21 Less credits $ TOTAL $ 1460.21 , 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: 1 d 1 Signature: NOW, nC:?. 1_. 20j6S--1 Amy F. Doyle x/87062 Daniel F. Wolfs n x/20617 Bruce H. Cherki #18837 Philip C. Warholic x/86341 Ronald M. Abramson x/94266 Ronald S. Canter x/94000 Donald P. Shiffer x/89451 Andrew C. Spears x/87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 JUDGMENT ISANTERED AS ABO/yE. Prothonotary/Cle ivV Division Deputy PRAEDJ/PANOJ W&A FILE NO. 128787938 c F5 COMMONWEALTH OF PENNSYLVANIA n.nl iNTY OF- CUMBERLAND Mag. Dist. No 09-1-02 Mod Name: Hon. ROBERT V. MANLOVE , Address: 1901 STATE' ST CAMP HILL, PA Telephone (717) . 761-0583 17011-0000 COLONIAL CREDIT CORP/A MD CORP 267 E MARKET ST C/O WOLPOFF & ABRAMSON YORK, PA 17403 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE ` NAME and ADDRESS rCOLONIAL CREDIT CORP/A MD CORP 267 E MARKET ST C/O NOLPOFF & ABRAMSON LYORK, PA 17403 J VS. DEFENDANT: NAME and ADDRESS rBAL&O, LISA A 422 N ENOLA'DR APT/STE H ENOLA, PA 17025-2253 L J Docket No.: CV-0000164-05 Date Filed: 4/11/05 THIS IS TO NOTIFY YOU THAT: Judgment: nX711iLT JDTIGdEm, PLTF ® Judgment was entered for: (Name) rnT.nMTAT. riawnTT rngP/A Mn rnxv ® Judgment was entered against: (Name) BAT.i T.TSA A in the amount of $ T , 411.2'I on: (Date of Judgment) s12 3/n5 Defendants are jointly and severally liable. Damages will be assessed on: This case dismissed without prejudice. Amount-Judgment Subject to ? Attachment/42 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ (Date & Time) Amount of Judgment Judgment Costs. Interest on Judgment Attorney Fees Total Post Judgment Credits Post Judgment Costs Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTOONOTARY/CLERK OF THE COURT OF?COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. 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 MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. My commission expires first Monday of January, Ah District Judge AOPC 315-05 DATE PRINTED: 5/24/05 10:17:59 AM ? n Ti- a s fi w O _n C'r N 0 =', 7 S! c:D y 342 IN THE COURT OF COMMON PLEAS OF Ckk(nrx?lana COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION No. P.O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff Vs. CIVIL ACTION - LAW LISA A BALKO Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: COLONIAL CREDIT CORPORATION ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF WELLS FARGO BANK P.O. BOX 1877 ROCKVILLE, MD 20849-1877 and certify that the last known address of the within Defendant(s) is: LISA A BALKO 422 N ENOLA DR APT H ENOLA PA 17025-2253 ka-"U"- Amy F. Doyle #87062 Daniel F. Wolfs #20617 Bruce H. Cherkis #18837 Philip C. Warholic x/86341 Ronald M. Abramson x/94266 Ronald S. Canter x/94000 Donald P. Shiffer x/89451 Andrew C. Spears #87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Pr actice of Debt Collection 4660 Trin dle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303 -6700 PCRES/PANOd W&A FILE NO. 128787938 c? ?, ?..> u c ?-s -;, ?, ? ^? " r; _?, ?_ -,-: n,. -? ; ;:. ?, `_ ? ?? - ?. U - ? . 341 IN THE COURT OF COMMON PLEAS OF CjkMFX,vj nCj COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION No. P.O. BOX 1877---- - ROCKVILLE, MD 20849-1877 Plaintiff VS. CIVIL ACTION - LAW LISA A BALKO 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, LISA A BALKO , above-named, is over 21 years of age; is last known to reside at 422 N ENOLA DR APT H ENOLA PA 17025-2253 County of CtumYx o 6 l,l , 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. Amy F. Doyle x/87062 Daniel F. Wo fson #20617 Bruce H. Che kis x/18837 COMMONWEALTH OF PENNSYLVANIA Philip C. Warholic x/86341 Notarial Seal Ronald M. Abramson x/94266 Dina A. Sweitzer, Notary Public Ronald S. Canter x/94000 Hampden Twp.,( umberlandCounty Donald P. Shiffer My Commission Expires Apr. 16, 2008 /89451 Andrew C. Spears x/87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 ( 7) 303-670 LHi SWORN and SUBSCRIBED to before me this day of y 20 'VIAL Not ry Public PNMAFF/PANOJ W&A FILE NO. 128787938 t? a ? % V-";i? .? [-' S` .{• ?-• ?? CT' ?? ` , ?' ?'? _ .. , C; ? ,._ ? ? 340 IN THE COURT OF COMMON PLEAS OF ?UX1YXY Cvd COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION NO. C) S - aVo CL c)i L?4/L! ?1 l P.O. BOX 1877 ROCKVILLE, MD 20849-1877 Plaintiff VS. LISA A BALKO 422 N ENOLA DR APT H ENOLA PA 17025-2253 Defendant(s) CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: LISA A BALKO 422 N ENOLA DR APT H ENOLA PA 17025-2253 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on t'?>CA_ L. /yiC/yiC in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award ( ) Judgment is in the amount of $ plus costs. ( X ) District Justice transcript of judgment in civil action in the amount of $ 1460.21 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: Pr honota If you have any questions regarding this Notice, please contact the filing party. G? v L Amy F. D yle N 7062 / Daniel F. Wolfson x/20617 Bruce H. Cherkis 8837 / Philip C. Warholic #86341 Ronald S. Canter 4000 / Ronald M. Abramson #94266 Donald P. Shiffer x/89451 / Andrew C. Spears x/87737 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa. R.C.P. 236.) DJNTC/PANOJ W&A FILE NO. 128787938 205 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 COLONIAL CREDIT CORPORATION IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF AMERICAN DEBT SALES CUMBERLAND COUNTY, PENNSYLVANIA ASSIGNEE OF WELLS FARGO BANK P.O. BOX 1877 .ROCKVILLE, MD 20849-1877 Plaintiff VS. JUDGMENT NO. 055240 LISA A BALKO 422 N ENOLA DR APT H ENOLA PA 17025-2253 PRAECIPE FOR WRIT OF EXECUTION ` (MONEY JUDGMENT) Defendant (s) ` To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, LISA A BALKO 422 N ENOLA DR APT H ENOLA PA 17025-2253 Defendant(s); (3) and against, SOVEREIGN BANK 310 EAST PENN DRIVE ENOLA PA 17025 Garnishee(s); (4) and index this writ (a) against, LISA A BALKO Defendant (s) and (b) against, SOVEREIGN 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) *** GARNISH ONLY *** You are directed to attach.the property of the Defendant(s) not levied upon in the possession of SOVEREIGN BANK . 310 EAST PENN DRIVE ENOLA PA 17025 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 $ 1460.21 Interest from 05/23/2005 To Be Determined At an interest rate of 6% per year Dated: Total $ 1460.21 Plus costs & interest ed: Amy F. Doyle 7062 / Daniel F. Wolfson #20617 Philip C. W holic #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, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road. 3rd Floor. Camn H;11_ PA 17n11 / !7171 IM-4-7nn .01 " . '?r. h? l (V r V 1 C? w N c -fAr Y N I Q t ? d 1 I I? • y V x WRIT OF EXECUTION and/or ATTACHMENT I ..- -.% COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COLONIAL CREDIT CORPORATION ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From LISA A BALKO, 422 N ENOLA DR APT H, ENOLA, PA 17025-2253 (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 SOVEREIGN BANK, 310 EAST PENN DRIVE, ENOLA, PA 17025 -- 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) 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 $1460.21 L.L. $.50 Interest FROM 5/23/05 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 28, 2006 (Seal) NO 05-5240 Civil CIVIL ACTION - LAW Curtis . 4Longq,ProthdToTaiyy By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3" FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 } a 1 10105/2006 THU 10:29 FAX 12006/020 oS - SZ t?rd AK.swe4-s -k> PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - LISA A BALKO 422 N ENOLA DR.APT A ENOLA PA 17025-2253 SS# XXX-XX-2116 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 IA. 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 of 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 at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) whic} are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s).. No ORALE2/PAWRIT W&A FILE NO. 128787938 10/05/2006 THU 10:29 FAX 0007/020 207 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. No 6. REAL PROPERTY: AT the time you were served or at any subsequent time, j did you hold legal, or equitable title to any property of any nature owned.' solely or in part by the Dgfendant(s) or in which and Defendant(s) held or claimed any interest? If o, describe for each Defendant(s) each item of property including its val 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 'ncludifig its value and the interest of Defendant(s). • j No I 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. Yes-See Attached Amy 'Y. D e #87062 / Daniel F. Wolfson #20617 Philip C Warhol'c #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson 1{•94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Date: ?C4 A Iaj005lOZO 10/05/2006 THU 10:29 FAX IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION NO. 055240 ASSIGNEE OF AMERICAN DEBT SALES Plaintiff vs. CIVIL ACTION-LAW LISA A BALRO 422 N ENOLA DR APT H ENOLA PA 17025-2253 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 AS41ST 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 11 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, and 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-2116 ORALEX/PAWRIT W&A FILE NO. 128787938 ANSWERS TO INTERROGATORIES Account # 0921703228 Balance: $1,790.50 Randolph L. Snyder, Jr Lisa A Balko 422 N Enola Dr Apt H Enola, PA 17025-2253 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 By: I i? Timothy J. Cooney OAG Team Leader Ca rv Q L37 A ?; UD ? Z i't'i N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Colonial Credit Corporation, Assignee of American Debt Sales VS. Lisa A. Balko 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: Amy F. Doyle, Esquire Wolpoff & Abramson, L.L.P. 4660 Trindle Road, 3`d Floor Camp Hill, PA 17011 Service by certified mail addressed as follows: Lisa A. Balko 422 N. Enola Drive, Apt H Enola, PA 17025-2253 1,7f Signature of Person Filing Timothy J. Cooney, OAG Team Leader Sovereign Bank MA1 M133-02-10 2 Morrissey Boulevard Boston, MA 02125 October 17, 2006 C) 0 C::) 1 f;?.. .,eat." rTi k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION Plaintiff VS. LISA A BALKO Defendant VS. Sovereign Bank Garnishee Garnishee: Sovereign Bank Court Order Processing Po Box 841005 Boston, Ma 02284 NO. 055240 CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, Sovereign Bank, in the amount of $895.25, as admitted in the answer to Interrogatories to be in the possession of Garnishee. The amount of the judgment together with interest and costs of the Plaintiff against the Defendant is $1,714.99. Dated: 8 Respectfully Submitted, f X , lk Amy F. Doyle #870 / Daniel F. Wolfson #2061 Philip C. Warholic # 341 / Andrew C. Spears #87737 David R. Galloway #87326 /Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 / Ronald S. Canter #94000 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 / (717) 303-6700 W&A File No. 128787938 n W 'V r 404. 10/05/2006 THU 10:29 FAX lub PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEPENDANT(S) - LISA A BALRO 422 N ENOLA DR, APT H ENOLA.PA...1.7025-2253 SS# XXX-XX-2116 16006/U1U 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 IA. 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 of 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 amounl 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 at any subsequent time, did you know of the existence of any other asset(s) of the Defendant(s) whic are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). No ORALE2/PAWRIT W&A FILE NO. 128787938 10/05/2006 THU 10:29 FAX 207 y. 14007/020 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. No 46 . 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 o, describe for each Defendant(s) each item of property including its yal 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 •ncludin$ its value and the interest of Defendant(s). i No ! 8. TRANSFER OF PROPERTY: At any time before or after you were served, di< 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. Yes-See Attached 17 _ Amy 'T. D e #87062 / Daniel F. Wolfson #2061 Philip C Warhol1 186341 / Andrew C. Spears #8773 David R. Galloway #87326 /*Tonilyn H. Chippie #8785 Ronald M. Abramson #94266 / Ronald S. Canter #9400 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Date: 9 u-6 A 6 10105/2006 THU 10:29 FAX 2US II 2005/020 IN THE COURT OF COMMON PLEAS OF'CUMBERLAND COUNTY, PENNSYLVANIA COLONIAL.CREDIT CORPORATION : NO. 055240 ASSIGNEE OF AMERICAN DEBT SALE. Plaintiff vs. CIVIL ACTION-LAW LISA A BALRO 422 'N ENOLA DR APT H ENOLA PA 17025-2253 ; 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 AS$IST THE CREDITOR'S EFFORTS TO SATISFY THE LAWFUL OBLIGATION OF THE ABOVE REFERENCED DEBTOR (S) . IMPORTANT NOTICES AND INSTRUCTIONS TO GARNISHE&, 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. 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, and 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-2116 ORALEX/PAWRIT W&A FILE NO. 128787938 ANSWERS TO INTERROGATORIES Account # 0921703228 Balance: $1,790.50 Randolph L. Snyder, Jr Lisa A Balko 422 N Enola Dr Apt H Enola, PA 17025-2253 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 unworn falsification to authorities. Sovereign Bank By: Timothy J. Cooney OAG Team Leader IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: Colonial Credit Corporation, Assignee of American Debt Sales VS. Lisa A. Balko 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: Amy F. Doyle, Esquire Wolpoff & Abramson, L.L.P. 4660 Trindle Road, P Floor Camp Hill, PA 17011 Service by certified mail addressed as follows: Lisa A. Balko 422 N. Enola Drive, Apt H Enola, PA 17025-2253 Signature of Person Filing Timothy J. Cooney, OAG Team Leader Sovereign Bank MA1 M133-02-10 2 Morrissey Boulevard Boston, MA 02125 October 17, 2006 -c7 `:, L 900 6 l 100 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05240 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND COLONIAL CREDIT CORPORATION VS BALKO LISA A And now SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0009:15 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BALKO LISA A in the hands, possession, or control of the within named Garnishee SOVEREIGN BANK 310 EAST PENN DRIVE ENOLA, PA 17025 Cumberland County, Pennsylvania, by handing to GIZEM LESPERANCE (MANAGER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her true and made Sheriff's Costs: So answr? Docketing .00 " Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 . 0 0 V, io%o/q 10/05/ 06 Sworn and Subscribed to before me this day of By Deputy She i A.D 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COLONIAL CREDIT CORPORATION vs. LISA A BALKO Plaintiff NO. 055240 Defendant CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE To the Prothonotary: Kindly mark the judgment entered against the Garnishee, Sovereign Bank, in the above matter, satisfied upon payment of your costs only. Amy F. Doyler706T,// Daniel F. Wolfson #2q O47 Philip C. Warholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 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., Suite 300 Camp Hill, PA 17011 (717) 303-6700 W&A File No. 128787938 ? Q UN VII) - tRI , 1 s',_?s R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. ,- - Sheriff's Costs: Advance Costs: 150.00 ,, Sheriff's Costs 93.44 SUtj.. Docketing 18.00 56.56 (9?poundage 1.84 - Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 07/17/07 Mileage 12.32 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage .78 Garnishee TOTAL 9.00 93.44 7? a Y / 07- So Answers- R. Thomas Kline, Sheriff B C AV tA0Cd&/ y . - ! It :b V Z#ATS 9GOl f-a Q i ,. t 7?i ck. 9yGj' 0 06 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5240 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COLONIAL CREDIT CORPORATION ASSIGNEE OF AMERICAN DEBT SALES ASSIGNEE OF WELLS FARGO BANK, Plaintiff (s) From LISA A BALKO, 422 N ENOLA DR APT H, ENOLA, PA 17025-2253 (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 SOVEREIGN BANK, 310 EAST PENN DRIVE, ENOLA, PA 17025 -- 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) 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 $1460.21 L.L. $.50 Interest FROM 5/23/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Due Prothy $1.00 Other Costs Plaintiff Paid Date: SEPTEMBER 28, 2006 (Seal) Curtis R (Long, Protho By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3PJ'FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062