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HomeMy WebLinkAbout06-0267 811 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. O~ - ~/'1 C.iu~l't~ P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant (s) PRAECIPE FOR JUDGMENT Mr. /Ms. Clerk: Please enter PATRICK R BRENNAN pursuant to the District Judgment in favor of Plaintiff and CHRISTINE M Justice Transcript. and against Defendant(s), BRENNAN ( X ) Amount due Less credits TOTAL $ 2541.15 $ $ 2541.15 , plus interest and costs ( X) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. DATE: ---1/~ )Oll Signature: C Amy F. Doyle ------- 1187062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / 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 (71 7) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 NOW,. J':\. \ II - , 20~. JUDGMENT Protho By: Deputy PRAEDJ/PANOJ W&A FILE NO. 122921626 '-- :) -; I :'~ n~ c..) ~,... ~..iJ <.':~ .< ". "~"", COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CmmERLAlIID $ NOTICE OF JUDGMENtrtRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS 'GREAT SDBCA l"INAllCIAL CORP. -, 267 BAST MARKET ST. C/O WOLPOPP & ABRAMSON ~ORK, PA 17403 ~ VS. Mag Dist. No. 09-3-04 MDJ Name: Hon THOMAS,A. PLACEY Add"" 104' S SPORTING HILL :an MECHARICSBURG, PA ' Telephoo<, (717) 761":8230 11050 DEFENDANT: NAME and ADDRESS fiRBJilRAll, PATRICK: R, ET AL. 42 VILLAGE COURT MECHARrcSjU:R.G~ PA 17050-9166 " L -, GREAT SBRBCA PIRARCIAL CORP. 267 BAST MARKET ST. C/O WOLPOPP & ABRAMSON YORK, PA 17403 ~ . Docket No,: CV-0000125-05 Date Filed:3/nlo5 THIS IS TO NOTifY YOU THAT: ,Cd . ::h.ldgmllnt: ' ' " J.__ ':> "#'~ .. "".."/,JjKPAOL.... JtlI)t:!U1ftI'I"PLTP, __ ' , --, ' if''; [i] Judgment was entered for: (Name) dVVa.'I' A1l1II'RC"a. 'P'TWa.WC"Ta.T. t"nV1> [i] Judgment was entered against: (Name) 'RVtzWRa.W 1>a.T1lTC'll: 11 in the amount 01 $ 2,!i41 1!i on: (Date of Judgment) 4/14/00; ,~:" o Defendants are jointly and severally liable, o Damages will be assessed on: (Date & Time) O Amount of Judgment Subject to Attachmenti42 Pa,C,S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 2,454.15 Judgment Costs $ 87.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2,541.15 Post Judgment Credits $ Post Judgment Costs $ ------------ ------------ Certified Judgment Total $ ~; 8 o This case dismissed without prejudice, ~; "'~ ANY PARTY HAS THE.RIGHT TO liP,' PEAL;W!THIN 30 DA'I;S AFTER THE ENTRY OF JllDGMENT 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 JUDGMENTfTRANSCRIPT 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 ND FURTHER PROCESS MAYBE 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. ~Date , Magisterial District Judge ify t at this is a true a d correct copy of the record of the p oceedings containing the' judgment. '4- 65 Date --- ~ ~:> , Magisterial District Judge My commission expires first Monday of January, 2010 ' SEAL AOPC 315.05 DATE PRINTED: 4/14/05 2:56:38 PM c "" C.::- =:. c} =;> 0-' " C- ..... :'-"" :T " -".'" nl ...,- 17:':': ~ Y "~ " r --", ?" ) (>>>J ,_5 [:n :..-l - ),~~ :D c.J .< .. "". .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBBlIT.lI.JI1D Mag, Dist. No 09-3:"04 NOTICE OF JUDG~E~t~NSCRIPT CIVIL CASE PLAINTIFF: NAME ;tnd ADDRESS 'GlUlAT SBRBCA FIlIABCIAL CORP. I 267 BAST HAlITRT ST. C/O WOLPO:rF & ABRAMSOll ~ORK, PA 17403 ~ VS. MDJ Name: Hon. THOMAS A. PLACBY Add"" 104 S SPORTIlIG HILL RD MBCIlABICSBURG, PA Telephoce (717) 761-8230 17050 NAME bnd ADDRESS R, ET AL. 'l GlUlAT SBlIBCA FIJII'AlICIAL CORP. 267 BAST MAltXBT ST. No.: C/O WOLPOFF & ABRAMSOll Date Filed: YORK, PA 17403 THIS IS TO NOTIFY YOU THAT: Judgment: DBI'AULT :rrmlDfll!N'!' PLTP [iJ Judgment was entered for: (Name) l1l1l1!lI.'I' A'1I!I\11lC'lI. lI'TlIlI.lIC'TlI.T. t"nll1> [iJ Judgment was entered against: (Name) ~1I11!111111l1.lI NnlT8'1'T1IIW M in the amount of $ 2,0;41 ,.'"!; on: (Da~ 0.1 Judgment) 4/14/00; o Defendants are jointly and severally liable. o Damages will be assessed on: o This case dismissed without prejudice, O Amount of Judgment Subject to Attachment/42 Pa,C,S. S 8127 $ o Portion of Judgment for physical damages arising out of residential lease $ ,JDate & Time) ;-" Amount of Judgment $ 2.454.15 Judgment Costs $ 87.00 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 2.541.15 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 JUDGMENTITRANSCRIPT 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 SATISFACTlON'WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PA YS IN FULL, . \.. "', ,"~'" SETTLES, OR OTHERWISE COMPLIES WITH THE JUOGME~T. I ce 'fy th t this is a true a d correct 4 14 DS Date Magisterial District Judge of the:!) oceedings containing the judgment. , Magisterial District Judge ~Date My commission expires first Monday of January, 2010 SEAL AOPC 315.05 DATE PRIlITBD: 4/14/05 2:56:59 PM ~ ;:cJ ~ ~ ft. t "- C) ....., .-() .~:;) 0 c~ \';,:..) ., 0:;;::1'''' - ~ '- :..-:1 M "'" " rci1:D ~ -, ,- ;j nl -U crJ 0- , .' C--) ~ ~ t2 ~ " . ",. ",': , ,~;-, "'-.1 -...0 GO ~jril ~ ~ ~:--. r -" c.) ~D w .-<: ~ ! '/~ (.:/f( 810 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 01.. - dll-1 CiUtL~~ P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant (s) 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 AMERICAN DEBT SALES, ASSIGNEE DF WELLS FARGO BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: PATRICK R BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050,9166 CHRISTINE M BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050-9166 C Amy F. Doyle #87062 / Philip C. Warho1ic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trind1e Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter #20617 1187737 1187852 1/94000 PCRES/PANOJ W&A FILE NO. 122921626 r' ,-~- .l ;,; ,C. ~ C~'. .,' -- (j./ .. .."- Ct', 809 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. Df.- - :JI, 1 CIO{~~ , P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN 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, CHRISTINE M BRENNAN above-named, is over 21 years of age; is last known to reside at 42 VILLAGE CT MECHANICSBURG PA 17050-9166 County of CUMBERLAND the United States or Servicernembers Civil , Pennsylvania; is not in the military service of its Allies, or otherwise within the provisions of the Relief Act and its Amendments. COMMONW!AL.TH OF PENNSYLVANIA Notarial Seal Kimberly L. Eisenhauer, Notary Public Hampden Twp.. Cumberland County My Commission Expires Nov. 17,2009 Member, Pennsytvania AssociatIon 01 Notatles C Amy F. Doyle'---- #87062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / 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 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 1187852 1194000 SWORN and SUBSCRIBED to before me this ,,- ~ day of JQf'LlCl.I\li ,20Ct..a. Notary Public PNMAF2/PANOJ W&A FILE NO. 122921626 C'. C. (J -\1 ::;-1 i;'\ L_ c.) .- c~~ BOB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. Dls. -.;ll, 7 C,uLT~ : P.O. BDX 1651 ROCKVILLE, MD 20B49-1651 Plaintiff vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant (s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I 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, PATRICK R BRENNAN , above-named, is over 21 years of age; is last known to reside at 42 VILLAGE CT MECHANICSBURG PA 17050-9166 County of CUMBERLAND the United States or Servicemembers Civil , Pennsylvania; is not in the military service of its Allies, or otherwise within the provisions of the Relief Act and its Amendments. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kimbe~y L. Eisenhauef. Notary Public Hampden Twp" Cumberland County My Commission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries (. Amy F. Doy-re- 1187062 / Philip C. Warholic #86341 / David R. Galloway #87326 / Ronald M. Abramson #94266 / Bruce H. Cherkis #lBB37 WOLPOFF & ABRAIlSON, L.!..P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter 1120617 1187737 #B7B52 1194000 SWORN and SUBSCRIBED to before me this 5 day of \.)OnllO.M~ ' 20W. ;"!-I),JDUllJlJfi~~J'b'jA /. /-.. _ Nta y Public (f PNMAFF/PANOJ W&A FILE ND. 122921626 , ':.:' , () -q ---I ~I- j;'i "., --:-1 (.:1 C~. ..<.. 807 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. 01.:. - :<~7 (!,u~c-,-~ " P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050-9166 Defendant (s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: PATRICK R BRENNAN CHRISTINE M BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050-9166 42 VILLAGE CT MECHANICSBURG PA 17050-9166 You are hereby notified that the following ORDER, entered against you on ,):;7.. \. II .:l(:JI'..lb of Pa. R.C.P. 236. ' DECREE or JUDGMENT has been in accordance with the provisions ( ) ( ) ( ) ( ) ( X ) Decree Nisi in Equity Final Decree in Equity Judgment of ( ) Confession ( ) Defau1 t ( ) Non-pros Judgment is in the amount of $ District Justice transcript of judgment of $ 2541.15 , plus costs. If not satisfied within sixty (60) days, your motor vehicle license will be suspended by the Pennsylvania Department of Transportation. ( ( ( ) ) ) Verdict Non-suit Arbitration Award , plus costs. in civil action in the amount ( ) operator's By: ,f.,~ If you have any questions regarding this Notice, please contact the filing party. ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff NO. 06267 vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant( s) CERTIFICATE PREREQUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULES 3117 & 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 3117 and 4009.22, Plaintiff certifies that: (I) a notice to serve the subpoena with a copy of the subpoena attached thereto was mailed or delivered to each party at least twenty (20) days prior to the date on which the subpoena is sought to be served, (2) a copy of the notice of intent, including the proposed subpoena, is attached ot this certificate, (3) no objection to the subpoena has been received, and (4) the subpoena which will be served is identical to the subpoena which is attached to the notice of intent to serve the subpoena. Date: ~17/f>" Amy F, Doyl #87062 Daniel F. Wo son #20617 Philip C. Warholic #8634 I 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, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3" Floor Camp Hill, PA 1701 I (717) 303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff NO. 06267 vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant CERTIFICATE OF COMPLIANCE WITH SUBPOENA TO PRODUCE DOCUEMNTS OR THINGS FOR DISCOVERY PURUSUANT TO RULES 3117 & 4009.23 TO: COMMONWEALTH OF PENNSYLV ANI WALNUT STREET HARRISBURG, PA 17001 I, ,certifY to the best of my knowledge, information and belief that all documents or things required to be produced pursuant to the subpoena issued on (date of subpoena) have been produced. Date: (Person served with the Subpoena) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANC[AL CORP Plaintiff NO. 06267 vs. CIV[L ACTION - LAW PATR[CK R BRENNAN CHRISTINE M BRENNAN Defendant( s) NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS OR DISCOVERY PURSUANT TO RULES 3117 & RULE 4009.12 Plaintiff intends to serve a subpoena identical to the one that is attached to this notice. You have twenty (20) days from the date listed below in which to file ofrecord and serve upon the undersigned an objection to the subpoena. If no objection is made the subpoena may be served. Date: J./rl /0 4 tv Amy . Doy[e # Danie[ F. Wolfs #20617 Philip C. Warho[ic #8634 [ Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Rona[d M. Abramson #94266 Rona[d S. Canter #94000 Bruce H. Cherkis # [ 8837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trind[e Rd., 3'd F[oor Camp Hill, PA [70[[ (7 [7) 303-6700 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff NO. 06267 vs. CIVIL ACTION - LA W PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant(s) SUBPOENA TO PRODUCE DOCUMENTS OR THINGS FOR DISCOVERY PURSUANT TO RULES 3117 & 4009.22 TO: COMMONWEALTH OF PENNSYL V ANI Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things to Wolpoff & Abramson, LLP, 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011: I. All documents indicating the bank and bank account number of Defendant. 2. All documents indicating where direct deposits of Defendant are deposited, including the name of the bank or financial institution, the account number into which it is deposited, and the routing number of the bank or financial institution. 3. All canceled checks for the past twelve (12) months naming Defendant as the payee. If you are not in possession of canceled checks, please provide the name and address of the person or entity where Plaintiff can obtained copies of such checks. 4. The application for employment of the Defendant. 5. All documents that constitute or refer in any way, directly or indirectly, to any and all books, records, or other memoranda of business or financial conduct, activities, status, or income of Defendant for the last two years. This includes financial statements prepared by or on behalf of Defendant. 6. All documents, items, and things that refer in any way, directly or indirectly, to ar:y and all accounts (business or personal bank, checking, savings, credit union, or retirement) in which Defendant has an interest. 7. All documents that contain or refer in any way, directly or indirectly, to the names and addresses of persons who have served as accountants, bookkeepers, or financial advisers for Defendant in the last tive years. 8. All documents that evidence or refer in any way, directly or indirectly, to the amount of money owed to Defendant by any person or entity. 9. All documents that refer in any way, directly or indirectly, to each person who has served as the banker or entity that has served as the bank for Defendant in the last two years. 10. All documents that refer in any way, directly or indirectly, to any cash on hand or in bank accounts or in financial institutions for Defendant as of the date of the production of documents. II. All documents that refer in any way, directly or indirectly, to any and all cash in any account owned or claimed by Defendant held or deposited with any bank or other tinancial institution. 12. All documents that refer in any way, directly or indirectly, to any shares of stock owned by Defendant or in which Defendant has an interest. 13. All documents that refer in any way, directly or indirectly, to any interest Defendant may have in any businesses, partnerships, corporations, or joint ventures. 14. All documents that refer in any way, directly or indirectly, to the rate of pay of the judgment Defendant, the yearly salary of Defendant for the last two years. 15. All documents that refer in any way, directly or indirectly, to any insurance policies and/or annuity contracts in which Defendant has an interest or that insure property in which Defendant has an interest or any insurance payments made by Defendant in the last four years and any insurance payments due or to become due to Defendant. 16. All documents that refer in any way, directly or indirectly, to any outstanding contracts for which Defendant is entitled to receive a commission and/or on which Defendant claims a right to receive a commission, whether a partial commission or complete commission. 17. All documents that constitute or refer in any way, directly or indirectly, to any records of salaries, commissions, bonuses, income from employment, allowances, expenses, or any other amounts of money paid to or by Defendant within the last two years. 18. All documents that contain or refer in any way, directly or indirectly, to the name and address of any person who has custody of records of salaries, commissions, bonuses, allowances, expenses, or any other amounts of money paid to or by Defendant within the last tive years. 19. All W-2s filed with the Social Security Administration. You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of compliance, to the party making this request at the address listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena may seek a court order compelling you to comply with it. This subpoena was issued at the request of the following attorneys: 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, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3'd Floor Camp Hill, PA l7011 (717) 303-6700 Date: BY THE COURT: By Prothonotary -~----~-<---..- c~ ...,., , .--' . ~, f'+') ~- .< f," G) .~ ~ - 7429 , . ..... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF AMERICAN DEBT SALES, ASSIGNEE DF WELLS FARGO BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. JUDGMENT NO. 06267 PATRICK R BRENNAN CHRISTINE M BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050-9166 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (MDNEY JUDGMENT) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, PATRICK R BRENNAN CHRISTINE M BRENNAN 42 VILLAGE CT 42 VILLAGE CT MECHANICSBURG PA 17050-9166 MECHANICSBURG PA 17050-9166 (3) and against, MEMBERS FIRST FCU 10 SKYPDRT RD MECHANICSBURG PA 17050-232 (4) and index this writ (a) against, PATRICK R BRENNAN CHRISTINE M BRENNAN (b) against, MEMBERS FIRST FCU as a lis pendens against the real property of the Garnishee(s) as follows: (Specifically describe property) *** GARNISH ONLY , Defendant (s) ; , Garnishee(s); , Defendant(s) and , Garni shee (s) , Defendant(s) in the name of the *** You are directed to attach the property of the Defendant(s) not levied upon in the possession of MEMBERS FIRST FCU 10 SKYPORT RD MECHANICSBURG PA 17050-232 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 Interest from 04/14/2005 At an interest rate of 6% per year $ 2541.15 To Be Determined Dated: ~ Amy F. Doyle 1187062 ! Daniel F. Wolfson 1120617 ~:~~~PR~'G:~~:~;~c ~~~~~~ j~~_'f Ronald M. Abramson #94266 / Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPDFF & ABRAMSON, L.L.P. ! Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor. Camo Hill. PA 17011 / (717) ~n~-~7nn L Total $ 2541.15 Plus costs & interest S fJ, +- ~ '- ~ - - ~ :S. P F ~ t "'V~ ~ ~ ~ ~ ~-fQ . ---- B ~ ~~ (J ~ ~ --- ~ ~ ~ II"( R..J Vl 'I'-" Vi \:' ~ Cr{ \ \ I I C> G:tJ ~\~~F _'\ _ (dE: - ~w- \ - i -----, 0 e-' C? 0 C c::~;'l- -n .... :~ '::::,.... (l ~ .-4 ::c ~-;:.. ~~~ :;0 - ...(=9 --l ~,,) i -,},O ,~ -t', '""" {S:11 ::.r.: ~;. C) ~ (5("'n ::;:l c ~~ ('~ - -- WRIT OF EXECUTION and/or ATTACHMENT . COMMONWEALTH OF FEJ'o<'NSYL VANIA) COUNTY OF CUMBERLAND) NO 06-267 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP" A MARYLAND CORP ARATION, Plaintiff (s) From PATRICK R. BRENNAN AND CHRISTINE M. BRENNAN, 42 VILLAGE CT., MECHANCISBURG, PA 17050-9]66 (I) 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 MEMBERS FIRST FCU, 10 SKYPORT RD., MECHANICSBURG, PA 17050-232 - GARN]SHEE - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2541.15 L.L. $.50 Interest FROM 4/14/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Corom Atty Paid $37.25 Plaintiff Faid Date: MARCH ]7, 2006 % Due Frothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary C ~c;/A o--.--e . t:. 7l1/l ;YJ~ / Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD 3RD FLOOR CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 7] 7-303-6700 Supreme Court ID No. 87737 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP Plaintiff NO, 06267 vs. CIVIL ACTION - LAW PATRICK R BRENNAN CHRISTINE M BRENNAN Defendant(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Members First FCU, discontinued, upon payment of your costs only, Dated: <f/<f/Ol, Amy F. Doyle #8 Daniel F, Wolfso #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 #\ 8837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3" Floor Camp Hill, PA 170/1 (717) 303-6700 W&A File No, 122921626 ~ -b (") lf1 ~ 7'\\- ''6 - -J - - ~ ~ ~ ~ t:. r ..,..-; ',< , (.,", 141 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., A MARYLAND CDRPORATION, ASSIGNEE DF AMERICAN DEBT SALES, ASSIGNEE OF WELLS FARGO BANK, N.A. P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff No. 06267 vs. CHRISTINE M BRENNAN 42 VILLAGE CT MECHANICSBURG PA 17050-9166 Defendant (s) PRAECIPE TO SETTLE AND SATISFY PLEASE MARK THE ABOVE-CAPTIONED ACTION AS SETTLED, SATISFIED AND DISCONTINUED. Respectfully submitted, By: u Amy . Doyle #87062 / Philip C. Wa #86341 / David R. Gall way #87326 / Ronald M. Abramson #94266 / 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 Daniel F. Wolfson Andrew C. Spears Tonilyn M. Chippie Ronald S. Canter tf20617 If87737 tf87852 1194000 cc: r;.(;t OADn/.JDA17J:.A I.U'.A 'C'TT'C' lUn l??O?lt:..?&. ^ :-i-~ :-:. ::-:i ("--, (.";:- ,-;', SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00267 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS BRENNAN PATRICK R ET AL ,Sheriff or Deputy Sheriff of And now MICHAEL BARRICK Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:50 Hours, on the 23rd day of March , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , in the BRENNAN PATRICK R hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to BRIAN PETERS (BRANCH MANAGER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: Docketing Service Affidavit Surcharge So ?,~~P .00 .00 .00 .00 .00 .00 R. Thomas Kline Sheriff of Cumberland County 03/24/2006 this of 1vL"-Y By - Sworn and subscribed to before me ~/--'" ~ ~ ~ ~ ~ R. Thomas Kline, Sheriff, who being duly sworn accQrding to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 18.00 1.68 .50 1.00 4.40 30.00 20.00 .78 9.00 II () 85.36 ./ IOJI"! 01, ~ StJ:1 d Cll:IVW qUal Vj.j~~~sI03J UNV',iJ.3tu.mJ HI .;jO 3JI.:J.:JO Advance Costs: 150.00 Sheriffs Costs 85.36 64.64 Refunded to Atty on 10/04/06 So Answers; ~~~~ R. ThO~ Kline, ~ff / ByC~tluJr~~ ~ ~ ~ ~J\~ '/ /;..~ \'", ' 6: ~ T \, <J .... )..l " ~ cu. .; {?l> '{ I~UI' i r'ffOl, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A NO 06-267 Civil CIVIL ACTION - LAW MARYLAND CORPARATION, Plaintiff(s) From PATRICK R. BRENNAN AND CHRISTINE M. BRENNAN, 42 VILLAGE CT., MECHANCISBURG, PA 17050-9166 (I) 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 MEMBERS FIRST FCU, 10 SKYPORT RD., MECHANICSBURG, P A 17050-232 - GARNISHEE - ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2541.15 L.L. $.50 Interest FROM 4/14/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $37.25 Plaintiff Paid Date: MARCH 17, 2006 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Pwthonotary ~ ~ fh< P. :!lAc -4: r- Deputy REQUESTING PARTY: Name ANDREW C. SPEARS, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRlNDLE ROAD 3RD FLOOR ,CAMP HILL, P A 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87737 <"