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HomeMy WebLinkAbout05-6792906 0, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. ASSIGNEE OF PROVIDIAN NATIONAL l BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS,'NJ 07632 Plaintiff Vs. , DOUGLAS E PRIAR Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: , Please enter Judgment in favor of Plaintiff and against Defendant(s), DOUGLAS E PRIAR and pursuant to the District Justice Transcript. ( X ) Amount due $' 7963.58 Less credits $ TOTAL' $ 7963.58 , 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: Signature: , r , Amy F. Doyle #87062 / Daniel F. Wolfson x/206.17 . Philip C. Warholic #86341 /'Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #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 NOW, , 20(I$ , JUDGMENT ISNTERED AS ABOVAS ABOV . G 49, Protho o ary/Clerk, '-i D' ision By: Deputy PRAEDJ PANOJ W&A FILE NO. 141405539 1 t,. > t, a s [t ?J y( ! r ? . V '. t S MMMONWEALTH OF PENNSYLVANIA r,nl INITv nF CUMBERLAND Mag. Dist. No.'. 09-1-02 MDJ Name. Hon. ROBERT V. MANLOVE Addess' 1901 STATE ST CAMP HILL, PA Telephone: (717 ) 761-0583 17011-0000 ROBERT V. MANLOVE 1901 STATE ST CAMP HILL, PA 17011-0000 NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS FPALISADES COLL. LLC/PROVIDIAN NTNL? 4660 TRINDLE RD 3RD FLOOR &AMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rP-RIAR, DOUGLAS B 211 FOUR SEASONS LN APT/STE R ENOLA, PA 17025 L J Docket No.: CV-0000439-05 Date Filed: 9/01/05 THIS IS TO NOTIFY YOU THAT: Judgment: nxFAULT TMGMENT PLTF ® Judgment was entered for: (Name) PAT.Taaniza rnT.T. _ T.T.r/Pgnvrnrax ® Judgment was entered against: (Name) pgTAR, nDiTril S it in the amount of $ 'L, 961.59 on: (Dal f Judgment) Defendants are jointly and sever (Date & Time) DATE Damages will be asMdff: C TIFY THAT THIS A TRUE ppD ORRL T C PY This case dismissedT?iFfh?td? Amount of JudgmenT uu) BERT V. MANLUVIL Attachment/42 Pa.C.S. § 8127[$ISTPIC.T JUSTICE F7 Portion of Judgment for physical damages arising out of residential lease $ 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 PROTHONOTARY/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. .u,......_ `',+,. r r_ ? Date ?tagisteria Distrio4.Judge I certify that this is a truZanorre Zop ?th of "e roceedings cont iron the )udgment.__._., . l7 Date (Magisterial District Judge My commission expires first Monday of January, 2006. SEAL C Ss3 t AOPC 315-05 DATE PRINTED: 10/11/05 9:31:06 AM""'""" „, ? V v, f J ? F1 f 1 1 ? w: N ti ,? 2p?5 905 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r ti (PALISADES COLLECTION LLC No. ASSIGNEE OF PROVIDIAN NATIONAL BANK • 210 SYLVAN AVENUE 'ENGLEWOOD CLIFFS, N7 07632 Plaintiff VS. CIVIC. ACTION - LAW DOUGLAS E PRIAR 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 PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, N7 07632 and certify that the last known address of the within Defendant(s) is: DOUGLAS'E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 Amy F. Doyle x/87062 / Daniel F. Wolfson #20617 Philip C. Warholic #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 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/PAN07 __W&A FILE ern 141405539 ?,? r.. r - i'? T1 ? [. •'f ., -? ] -. ? ? l:: I y i. r ' • ''7 -- ?, 904 .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA " 1 PALISADES COLLECTION LLC No. C>.S (2L?,? l ?JL? ASSIGNEE OF PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. CIVIC. ACTION - LAW DOUGLAS E PRIAR 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, DOUGLAS E PRIAR , above-named, is over 21 years of age; is last known to reside at 211R FOUR SEASONS LN ENOLA PA 17025 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. , COMMONWEALTH OF PENNSYLVANIA Notarial Seal [MY erly L. Eisenhauer, Notary Public pden Twp., Cumberland County ommission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries +M Amy F. Doyle, #87062 / Daniel F. Wolfson x/20617 Philip C. Warholic x/86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #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 SWORN and SUBSCRIBED to before me this Z? day of C1?Cei,?C1 20CYD, ?f?I c .t_/1 -__ Notary Public PNMAFF/PANOJ _W&A FILE NO. 141405539 ,-I .- c`7 ,Y r?l 903 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 0-1 vL h?I'+?1 ASSIGNEE OF PROVIDIAN NATIONAL \? BANK 210 SYLVAN AVENUE' ENGLEWOOD CLIFFS, N7 07632 i Plaintiff I VS. CIVIL ACTION - LAW DOUGLAS E FRIAR 211R FOUR SEASONS LN ENOLA PA 17025 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT T0; DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 You are hereby notified .tkat the following ORDER, DECREE or JUDGMENT has been entered against you on g-c- 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 $ 7963.58 , 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; - Prothonotary 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 / 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, Camp Hill, PA 17011 / (717) 303-6700 (This Notice is given in accordance with Pa. R.C.P. 236.) 2456 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 056792 ASSIGNEE OF PROVIDIAN NATIONAL Plaintiff VS. CIVIL ACTION-LAW DOUGLAS E FRIAR 211R FOUR SEASONS IN ENOLA PA 17025 Defendant(s) ?rLSWGrS 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 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. ORALEX/PAWRIT W&A FILE NO. 141405539 SS// 177 42 2566 2454 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 SS# 177 42 2566 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. Defendant had account 536858913 with a balance of $118.12 at time served. The account is individually held. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. No 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons, give their full name and address. No 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. See answer to question 1. 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) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). See answer to question 1. ORALE2/PAWRIT W&A FILE NO. 141405534 2455 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. See answer to question 1. 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). See answer to question 1. 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant(s). No 8. TRANSFER OF PROPERTY: At any time before or after you were served, 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. Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Commerce 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. c No 601Paxtoen Bank Street 17111 134 Date Amy F. Doyle #87062 / Daniel Wolfson #20 Philip C. Warholic #86341 / David R. Galloway #87326 / Tonilyn M. Chippis #87 Ronald H. Abramson #94266 / Ronald S. Canter #94 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: I kit 106 ''° s', 2453 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION LLC IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF PROVIDIAN NATIONAL CUMBERLAND COUNTY, PENNSYLVANIA BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. JUDGMENT NO. 056792 DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant (s) To the Prothonotary: Please reissue the Writ of Execution in the above-captioned matter, (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 , Defendant(s); (3) and against, COMMERCE BANK 4 LEMOYNE DR LEMOYNE PA 17043-1229 Garnishee(s); (4) and index this writ (a) against, DOUGLAS E PRIAR , Defendant(s) and (b) against, COMMERCE 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) 211R FOUR SEASONS LN ENOLA PA 17025 All personal property of any nature located within the household or immediate vicinity of the Defendant(s) address and all other personal property within the dominion and control of the Defendant(s) wherever it is located shall be subject to the levy. ALSO: You are directed to attach the property of the Defendant(s) not levied upon in the possession of COMMERCE BANK 4 LEMOYNE DR LEMOYNE PA 17043-1229 , Garnishee (s) All accounts including all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securities, coupons and safe deposit boxes. Amount due $ 7963.58 Interest from 10/10/2005 To Be Determined At an interest rate of 6% per year Total $ 7963.58 Plus costs & interest Dated: _1 Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / #87737 David R. Galloway #87326 / onilyn 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 Floors_ Camv Hill. PA 17011 / (717) 303-1 ro I 4n ? -J acs ?' w' -% WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6792 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK, Plaintiff (s) From DOUGLAS E. PRIAR, 211 R FOUR SEASONS LN, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 4 LEMOYNE DR, LEMOYNE, PA 17043-1229 -- ALL ACCOUNTS INCLUDING ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OT 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 $7963.58 L.L. $.50 Interest FROM 10/10/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Due Prothy $1.00 Atty Paid $37.25 Plaintiff Paid Date: JULY 18, 2006 Other Costs CURTIS ONG Prothonotary (Seal) REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3RD FLOOR CAMP HILL, PA 17011 By: Deputy Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 +a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff vs. DOUGLAS E PRIAR Defendant vs. Commerce Bank Garnishee Garnishee: Commerce Bank 3801 Paxton St Harrisburg, Pa 17111 NO. 056792 CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, Commerce Bank, in the amount of $118.12, 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 $8,440.30. Dated: ?4 3 Respectfully Submitted, Amy F. Doyle #870 / Daniel F. Wolfson #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 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. 141405539 Z C? w Ln 1 F C,o .,, 21.56 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. 056792 ASSIGNEE OF PROVIDIAN NATIONAL Plaintiff VS. CIVIL ACTION-LAW DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 Defendant (s) INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: PURSUANT TO RULE 3114 OF THE RULES OF CIVIL PROCEDURE, THE FOLLOWING INTERROGATORIES HAVE BEEN SERVED UPON YOUR INSTITUTION. GARNISHEE IS HEREBY REQUIRED TO ANSWER EACH OF THE FOLLOWING INTERROGATORIES SEPARATELY AND FULLY. PLEASE COMPLETE THE FOLLOWING INTERROGATORIES TO ASSIST THE 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 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 additional information. F. Where exact information cannot be f rmation 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# 177 42 2566 ORALLY/PAWRTT W&A FTTY Nn_ 141405539 ., 2454 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - DOUGLAS E PRIAR 211R FOUR SEASONS LN ENOLA PA 17025 SS# 177 42 2566 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. Defendant had account 536858913 with a balance of $118.12 at time served. The account is individually held. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. No 2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent time, state whether or not the Defendant(s) maintains any safe deposit box or boxes. If so, include the identification number or other designation of the box or boxes. Include a full description of the contents and also the amount of cash among those contents. If the Defendant(s) maintains any of these jointly with any other person or persons, give their full name and address. No 3. PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not Defendant(s) owns any personal property that was in your possession and/or control. If so, include a full description of all personal property giving full value and present location. State also whether or not there are any encumbrances or liens holders, the present balance of the encumbrance. State where and when the encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. See answer to question 1. 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) whict are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). See answer to question 1. ORALE2/PAWRIT W&A FILE NO. 141405539 _- 2455 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. See answer to question 1. 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). See answer to question 1. 7. PROPERTY HELD AS A FIDUCIARY: At the time you were served or at any subsequent time, did you hold as a fiduciary any property in which any Defendant(s) had an interest? If so, please describe for each Defendant(s) the nature of the property including its value and the interest of Defendant (s) . No 8. TRANSFER OF PROPERTY: At any time before or after you were served, 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. Defendant made deposits into the above referenced account in the ordinary course prior to service, none of which were at the direction of Commerce Bank, 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. No \ A , -- Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / 4gidrew C. Spears #8P37 David R. Galloway #87326 / Tonilyn M. Chippie #87852 mmerce Bank Ronald M. Abramson #94266 / Ronald S. Canter #94000 1 Paxton Street Bruce H. Cherkis #18837 ;burg, PA 17111 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff M613 4 Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 ate 4 (717) 303-6700 Date: -7 6' 106 aU? ? p ? 2046 i SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06792 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS PRIAR DOUGLAS E And now SHANNON SHERTZER ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 1000:00 Hours, on the 24th day of July , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , PRIAR DOUGLAS E hands, possession, or control of the within named Garnishee COMMERCE BANK 4 LEMOYNE DRIVE LEMOYNE, PA 17043 Cumberland County, Pennsylvania, by handing to in the JASON THOMAS, CUSTOMER SERVICE REPRESENTATIVE , personally three copies of interogatories together with THREE true and attested copies of the within WRIT OF EXECUTION, INTERR and made the contents there of known to His Sheriff's Costs: So answers-...-..-.,,,.. Docketing .00 r Service .00 Affidavit .00 R. Thoma's Kline Surcharge .00 Sheriff of Cumberland County 00 00 00/00/0000 Sworn and Subscribed to n1 before me this day of By eputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 056792 vs. DOUGLAS E. PRIAR Defendant CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE To the Prothonotary: Kindly mark the judgment entered against the Garnishee, Commerce Bank, in the above matter, satisfied upon payment of your costs only. Amy F. oyle #87062 Daniel F. Wolfson #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., Suite 300 Camp Hill, PA 17011 (717) 303-6700 W&A File No. 141405539 ?V 44 P rv M ??f r R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 125.04 Docketing 18.00 $ 24.96 Poundage 2.46 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 02/12/07 Mileage 14.08 Surcharge 40.00 Levy 40.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage z/fs A TOTAL $ 125.04 o Answers; R. Thomas Kline, Sheriff -- Qjl4auia?A. 4n' ?'?. ' Brewbaker m i , p cm- S v i ypv? OAJ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6792 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK, Plaintiff (s) From DOUGLAS E. PRIAR, 211 R FOUR SEASONS LN, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of COMMERCE BANK, 4 LEMOYNE DR, LEMOYNE, PA 17043-1229 -- ALL ACCOUNTS INCLUDING ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OT 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 $7963.58 L.L. $.50 Interest FROM 10/10/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Plaintiff Paid Date: JULY 18, 2006 Due Prothy $1.00 Other Costs C RTIS R. NG Prothonotary (Seal) REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, 3`D FLOOR CAMP HILL, PA 17011 By: Deputy Attorney for: PLAINTIFF