HomeMy WebLinkAbout05-6792906
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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 .
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Protho o ary/Clerk, '-i D' ision
By:
Deputy
PRAEDJ PANOJ W&A FILE NO. 141405539 1
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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
& 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.
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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
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AOPC 315-05 DATE PRINTED: 10/11/05 9:31:06 AM""'""" „,
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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
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904
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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
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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
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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
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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
--
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Brewbaker
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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