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
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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
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® 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
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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
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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
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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.)
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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
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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
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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
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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
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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.
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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
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Great Seneca Financial Corp.
Vs
Jamie L. Brown
Writ of Execution
Docket No. 2005-5359 Civil Term
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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:
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R. Thomas Kline, Sheriff
BY (;
Sergean
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