Loading...
HomeMy WebLinkAbout05-5359893 IN THE COURT OF COMMON PLEAS OF CUMBERLAND GREAT SENECA FINANCIAL CORP., NO. UJ - P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. JAMIE L BROWN Defendant(s) Mr./Ms. Clerk: COUNTY, PENNSYLVANIA 5?35? PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), JAMIE L BROWN and pursuant to the District Justice Transcript. ( X ) Amount due $ 1436.84 Less credits $ TOTAL $ 1436.84 , 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: 30 0? Signature: Amy F. Do a x/87062 / Daniel F. Wolfson #20617 Philip C. Warhol c #86341 / Andrew C. Spears #87737 David R. Galloway x/87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson x/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 NOW, 20 JUDGMENT IS EN RED AS ABOVE Prothonot ry/Cler vil Di ision Deputy PRAEDJ/PANOJ W&A FILE NO. 13207106n TI -r bT. CID ~'- > 'tti7 08/16/05 15:54 FAX 7177746684 COMMONWEALTH OF PENNSYLVANIA D J, CLEMENT ' ;L3 -/? 2002 UUUV 1 Y 09-1-01 MDJ Name: Han. CHARLES A. CL880E1=, OR Ad"gw, 400 SR=GIZ ST OLDS TOMIITB COMMONS -SDIT3 3 NSM CUAMZRLAND, PA reieaeanc (717) 774=5989 17070 GREAT SEHECA FINANCIAL CORP 267 EAST MARIK T ST C/O MOLPOFF & ABRAIIIISON YORE, PA 17403 THIS IS TO NOTIFY YOU THAT. Judgment: NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS rGREAT SENECA FINANCIAL CORP -71 267 BAST HARM ST ' C/O MOLPOFF a ABRAMSON LYORX, PA 17403 vs. DEFENDANT;' NAME wdAMRFSS FB-ROUX, JAMMIS L 533 NORTH SECOND ST APT/ST8 A LEISOYNE, PA 17043-1011 L Docket No.: CY-0000241-05 Date Fled:' 4/25105 I -i I ® Judgment was entered for: (Name) rso:'T awlvans naiwT&f milip ® Judgment was entered against: (Name) seRnwn[? r»,tTN T. in the amount of $ 10436-SA- on: ? Defendants are jointly and severally liable. ? Damages will be assessed on: (Date of Judgment) 8/16105 (Date & Time) This case dismissed without prejudice. AS OF 8116/05 JUDGEMFNT AMOUNT HAS BEEN CORRECTED........ Amount of Judgment Subject to ? Attachment142 Pa.C.S. § 8127 $ Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment Judgment Costs Interest on Judgment Attomev Fees' 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 PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTJTRANSCRIPT 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 TH A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGM DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. /!1 ? 1 n?? h? ------------------ 8/16/05 Date Magisterial District Judge I certify that this is a true and correct Co y of re ?thro gscontaining the judgment. 9' Oar Date Magisterial District Judge My commission expires first Mondav of Januarv.2001 c>=dI n3 " y ' uz -f] W ?' r5 _ n IT, GA ? Cs ;'rt SEP 1 ? ?n05 891 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP'., No. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. CIVIL ACTION - LAW JAMIE L BROWN 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, JAMIE L BROWN , above-named, is over 21 years of age; is last known to reside at 533A N 2ND ST LEMOYNE PA 17043-1011 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. Amy F1 Doyle v x/87062 / Daniel F. Wolfson x/20617 Philip C. War olic #86341 / Andrew C. Spears /87737 David R. Galloway x/87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 COMMONWEALTH OFYLVANIA WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff i Aa Attorneys in the Practice of Debt Collection unty Ro 4660 Trindle Road, 3rd Flo or , Camp Hill, PA 17011 , 2008 (717) 303-6700 SWORN and SUBSCRIBED to before me this W-Inday of J!(YlOIA , 20 ArD. _h" Notary Public PNMAFF/PANOJ W&A FILE NO. 132071060 C7 ci r" cry - ?j -F F r i _ ?'? -_-i L ?.? t•F 1 ?.- _ .i.?L_,.., W `J .n_ ?_ -?i C? ?? ..- i7 ?? ? 892 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff Vs. JAMIE L BROWN Defendant(s) No. CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 Amy F. Ddyle x/87062 / Daniel F. Wolfson #20617 Philip C. Warhol c #86341 / Andrew C. Spears x/87737 David R. Gallowa x/87326 / Tonilyn M. Chippie x/87852 Ronald M. Abramson //94266 / Ronald S. Canter x/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 PCRES/PANOJ W&A FILE NO. 132071060 ?? (`l ?? C? -Cl L 1 ^1 C:J ". G? ?? _(?1 `J? '? (?" ? 890 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 Defendant(s) NO. CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on Q/1?p5 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 $ 1436.84 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsyl vania Department of Transportation. By: P, othon r If you have any questions regarding this Notice, please contact the filing party. /Ii A , Amy F. Doyle x/87062 / Daniel F. Wol"f'son x/20617 Philip C. Warholi /86341 / Andrew C. Spears x/87737 David R. Galloway #87326 / Tonilyn M. Chippie x/87852 Ronald M. Abramson x/94266 / Ronald S. Canter #94000 Bruce H. Cherkis x/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 (This Notice is given in accordance with Pa. R.C.P. 236.) ?? `?+?' L r?`? o° ? ? c ? ?. c w hJ {`? C' .'. G? ?'} (? ?? iii Y ? ???) S?j 1 f;? _.- f5? PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 055359CIVIL PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 , Defendant(s); (3) (4) , Garnishee(s); , Defendant(s) and (b) against, M & T BANK , Garnishee(s), as a lis pendens against the real property of the Defendant(s) in the name of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of M & T BANK 1200 MARKET ST LEMOYNE PA 17043-1417 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 $ 1436.84 Interest from 08/16/2005 To Be Determined At an interest rate of 6% per year Dated: U(loIo ? V Total $ 1436.84 Plus costs & interest Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warhol' #86341 / ears #87737 David R. Galloway #87326 / ?j? Ronald M. Abramson #94266 / onald S. Canter #94000 and against, M & T BANK 1200 MARKET ST LEMOYNE PA 17043-1417 and index this writ (a) against, JAMIE L BROWN 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 W&A FILE NO. 132071060 1 V T ;? R, -O trti G7 .G w, G ?• WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 05-5359 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, N.A., Plaintiff (s) From JAMIE L. BROWN, 533A N 2No ST., LEMOYNE, PA 17043-1011 (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 M & T BANK, 1200 MARKET ST., LEMOYNE, PA 17043-1417 - 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) 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 $1436.84 L.L. $.50 Interest FROM 8/16/05 AT AN INTEREST RATE OF 6% PER YEAR Any's Comm % Due Prothy $1.00 Atty Paid $37.25 Plaintiff Paid Date: JUNE 9, 2006 Other Costs CURTIS NG 7 Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name TONILYN M. CHIPPIE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 31°o FLOOR CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87852 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. 055359CIVIL A MARYLAND CORPORATION, Plaintiff va. CIVIL ACTION-LAW JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 Defendant (s) Ahsocr-5 4v 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 yo . 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'iused, 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# 180 62 7417 ORALEX/PAWRIT W&A FILE NO. 132071-060 a w r 1+454 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - JAMIE L BROWN 533A N 2ND ST LEMOYNE PA 17043-1011 SS# 180 62 7417 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 identificjation numbers of those accounts, and the amount or amounts the Defendant(s) ha in each account. If the Defendant(s) maintains any of these jointly w?th any other person, oLV persons, give their name and address 0 Z-OOM "Tow LIL CJ) ?4 V) IA. DIRECT DEPOSIT ACCOUNTS: Are anyf the accounts listed above direct deposit accounts? If yes, please state t identification numbers of those accounts. Nvo 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 num er or other designation of the box or boxes. Include a full description of he contents and also the amount of cash among those contents. If the Defends t(s) maintains any of these jointly with any other person or persons, giv their full name and address. 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 ?dr , 4. OTHER ASSETS: At the time you were served or did you know of the existence of any other as et(s) are not disclosed in the preceding Interrogat ties. all details concerning those asset(s). ORALE2/PAWRIT W&A FILE NO. 132071060 at any subsequent time, of the Defendant(s) whick If so, please set forth i y» 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 ile"f v property including its value. 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). Na 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary ny property in which any Defendant(s) had an interest? If so, please escribe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s).. fv?' 8. TRANSFER OF PROPERTY: At any time before or after you were served, dii 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 deliverel including the dates of delivery or transfer and state the considerat on paid. 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. JUL 17 2006 BANK Date: 1,0 IV f Aml/ V. Doyle x/87062 / Daniel F. Wolfson $20 Philip C. Warholic #86341 / Andrew C. Spears 87 David R. Galloway #87326 / Ronald M. Abramson #94 66 / an or X94 Bruce H. Cherkis #18;37 WOLPOFF & ABRAMSON, L. .P. / Counsel for Plaintiff Attorneys in the Practce of Debt Collection 4660 Trindle Road, 3rd',Floor, Camp Hill, PA 17011 (717) 303-6700 I r> ?., _, -„ ,? c. .?. .:.. ? --rf'i ,? ' c i ?a ,_,? r . - --,. -? %'1; ;.:? "?. .. .-- ?r; f 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff vs. JAMIE L. BROWN Defendant And M&T BANK Garnishee To the Prothonotary: Kindly mark of your costs only. Dated: NO. 055359CIVIL CIVIL ACTION - LAW TO DISCONTINUE ATTACHMENT EXECUTION attachment against the Garnishee, M&T Bank, discontinued, upon payment Respectfully Submitted, f/, wl., ( ' /d Amy F. Doyle #062 Daniel F. Wolfs #20617 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., 3`d Floor Camp Hill, PA 17011 (717) 303-6700 W&A File No. C - P t\V^-ilk ^;r P W n Ua O'? U - Q SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05359 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS BROWN JAMIE L And now RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:40 Hours, on the 14th day of June , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , BROWN JAMIE L , in the hands, possession, or control of the within named Garnishee M & T BANK 1 WEST HIGH ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JESSICA REESE (HEAD TELLER personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION true and made the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge ?l qN /o t, Sworn and Subscri ed to before me this .00 .00 .00 .00 .00 . 00Z day of So answers: R. Thomas Kli e Sheriff of Cumberland County 06/15/2006 By r eputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP No. 055359CIVIL ASSIGNEE OF RECOVERY PARTNERS L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, N.A. CIVIL ACTION - LAW Plaintiff VS. JAMIE L BROWN Defendant(s) PRAECIPE TO SETTLE AND SATISFY Please mark the Judgment in the above-entitled cause as paid and satisfied. Respectfully Submitted, By: Amy F. Doyle #8Q062 Philip C. Warholic #86341 David R. Galloway #87326 e/ Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 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. 132071060-N -qgk• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP No. 055359CIVIL ASSIGNEE OF RECOVERY PARTNERS L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, N.A. CIVIL ACTION - LAW Plaintiff VS. JAMIE L BROWN Defendant(s) CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing praecipe was served this date by Regular Mail, Postage Pre-Paid on this day of 20?? JAMIE L BROWN 533A N 2ND ST EMOYNE. PA 17043 Amy F. Doyle #87062 Philip C. Warholic #863 / vid R alloway #873 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff C-) o { 31 m -r5 m Great Seneca Financial Corp. Vs Jamie L. Brown Writ of Execution Docket No. 2005-5359 Civil Term -7 Tr'4. P x .. i i ,+?li R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. No action has been taken in the last six months. Sheriff's Costs Docketing $18.00 Surcharge $30.00 Levy $20.00 Mileage $ 4.40 Poundage $ 1.66 Prothonotary $ 1.50 Garnishee $ 9.00 Total $84.56 So Answers: - 10 4? r-OOOR OO&? R. Thomas Kline, Sheriff BY (; Sergean cA 7-? 9 k6' 12?1113393a