HomeMy WebLinkAbout06-0841IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ?+,,
GREAT SENECA FINANCIAL CORP., - NO. 0",C /'-J"Yl
P.O. BOX 1651
ROCKVILLE, MD 20849
Plaintiff
vs.
BRIAN K WATERS
Defendant(s)
PRAECIPE FOR JUDGMENT
Mr./Ms. Clerk
Please enter Judg ent in favor of Plaintiff and against Defendant(s),
BRIAN K WATERS and
pursuant to the Distri t Justice Transcript.
( X ) Amount du? $ 1689.76
Less credits $ 695.00
TOT $ 994.76 , plus interest and costs
( X ) I certify?!that the foregoing assessment of damages is for specified
amounts alleged to be cue in the complaint and is calculable as a sum certain fro
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 par
who has appeared in thel action or to his/her Attorney of Record.
DATE: (Signature:
?- - Amy F. Doyle #87D62 / Daniel F. Wolfs
Philip C. Warholic #86341 / Andrew C. Spear
David R. Galloway 487326 / Tonilyn M. Chip
Ronald M. Abramson 494266 / Ronald S. Cante
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON, L.L.P. / Counsel for P1
Attorneys in the Practice of Debt Collectio
4660 Trindle Road, 3rd Floor, Camp Hill, PA
(717) 303-6700
NOW, 206(-> , JUDGMEN IS ENTERED ABOVE.
Pro onota erk, ivil Division
By:
Deputy
PRAEDJ/PANOJ W&A FILE NO. 123831739
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C 'I MONWEALTH OF PENNSYLVANIA
COHNTY OF CUMBERLAND
ling. Dist No..
09-3-04
IMVName. Hon.
TBIOMAS A. PLACEY
add"aid 104 S SPORTING BILL RD
MECHANICSBURG, PA
ode ('7L17) 761-9230 17050
GREAT SENECA FINANCIAL CORP.
267 EAST MARKET ST.
C/O WOLPOFF & ABRAMSON
YORK, PA 17403
NOTICE OF JUDGMENT/TRANSCRIPT
PLAINTIFF CIVIL CASNAME ar)n E ADDRESS
FGREAT SENECA FINANCIAL CORP.
267 EAST MARKET ST.
C/O 'vNOLPOFF & ABRAMSON
LYORK, PA 17403 J
VS.
DEFENDANT: NAME and ADDaES5
FWATERS, BRIAN K
826 MARKET STREET
DUNCANNON, PA 17020
L J
Docket No.: CV-0000156-05
Date Filed 4/04/05 ,
THIS IS TO NOTIFY YOU THAT:
:Judgment:
C] Judgment was entered for: (Name)
® Judgment was entered against: (Name) marQnaF IRRTAW X
in the amount of $ If 699.76 on: (Date of Judgment) S/, 210E
El Defendants are jointly and severally liable.
Damages will be assessed on:
El This case dismissed without prejudice.
Amount of Judgment Subject to
Attachment/42 Pa.C.S. § 8127 $
Portion of Judgment for physical
damages arising out of residential
lease $
(Date & Time)
Amount of Judgment $
6
1,621.2
Judgment Costs $ 68.50
Interest on Judgment $ .00
Attorney Fees $ .00
Total $ 1,689.76
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total --
$ ----------
ANY PARTY HAS THE MIGHT TO APPEAy WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERR 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 ?HE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PL AS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED INITHE 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.
c
Iy Date Magisterial District Judge
I certify that this is a true add correct c oceedings containing the judgment.
6 y C Dat Magisterial District Judge
My commission expires first Monday of January, 2010. SEAL'
AOPC 3I5-05 DATE PRINTED: 5/12/05 3:11237 PM
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CIVIL ACTION - LAW
CERTIFICATE OF RESIDENCE
PA. R.C.P. 236
I, hereby certify tlhat the precise residence of Plaintiff is:
GREAT SENECA FIINANCIAL CORP.,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
P No
0( Cain
GREAT SENECA FINANCIAL .,
COR .
b
P.O. BOX 1651
ROCKVILLE, MD 20649
Plaintiff
Vs.
BRIAN K WATERS
Defendant(s)
P.O. BOX 1651
ROCKVILLE, MD
and certify that the last
BRIAN K WATERS
826 N MARKET S'.
DUNCANNON PA
0849
known address of the within Defendant(s) is:
7020
Cx?----
I
III
PCRES/PANOJ W&A FILE No. 123831939
Amy F. Doyle
Philip C. Warholic
David R. Galloway
Ronald M. Abramson
Bruce H. Cherkis
WOLPOFF A ABRAMSON
Attorneys in the P
4660 Trindle Road,
(717) 303-6700
#87062
#86341
#89326
#94266
#18837
L.L.P
ca ctiCe
3rd F1
/ Daniel F. Wolfson #
/ Andrew C. Spears #
Tonilyn M. Chippie #
/ Ronald S. Canter #
Counsel for Plainti
of Debt Collection
>or, Camp Hill, PA 1701
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., N° U(?` a C?VIU v-'
P.O. BOX 1651
ROCKVILLE, MD 20849
Plaintiff
vs
BRIAN K WATERS
Defendant(s)
CIVIL ACTION - LAW
FFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
The undersigned co,kael, being duly sworn according to law, depose and say
that I am the Attorney f?br the Plaintiff in the above-captioned matter, and that to
the best of my kncwledge4 information and belief Defendant,
BRIAN K WATERS above-named, is over 21 years of age; is last
known to reside at 826 NIIMARKET ST
DUNCAMNON PA 19020
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 Rel?cf Act and its Amendments.
COMMONWEALTH OF PENNSYL NIA Amy F. Doyle #87062 / Daniel F. Wolfson #
Philip C. Wa rhol is #86341 / Andrew C. Spears #
Notarial Seal David R. Galloway #89326 / Tonilyn M. Chippie #
5"' y L. Eisenhauer, Notary Pu gc Ronald M. Abramson 494266 / Ronald S. Canter #
en Twp., Cumberland Cou ty B r u c e H . C h e r k i s # 1 8 8 3 9
ission Expires NOV. 17,209 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plainti
MBmbeL Pennsylvania Association of Not ties Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 1401
(917) 303-6780
?I I ?
SWORN and SUBSCRIBED to bg fore me this day of F.i2?_?C??-_C.
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Notary Public J
PNMAFF/PANOJ W&A FILE NO. 123931939
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., NO.
P.O. BOX 1651
ROCKVILLE, MD 20849
Plaintiff
VS. CIVIL ACTION - LAW
BRIAN K WATERS
826 N MARKET ST
DUNCANNON PA 17020
Defendant(s)
',NOTICE OF ORDER, DECREE OR JUDGMENT
TO: BRIAN K WATERS
826 N MARKET ST '..
DUNCANNON PA 17020
You are hereby notified) t t e following ORDER, DECREE or JUDGMENT has been
entered against you one . !p 4ILZ(o in accordance with the provisio
of Pa. R.C.P. 236.
( ) Decree Nisi in Equity
( ) Final Decr''ee in Equity
( ) Judgment oI f ( ) Confession ( ) Verdict
( ) Default ( ) Non-suit
( ) Non-pros ( ) Arbitration Award
( ) Judgment is in the amount of $ 994.76 , plus costs.
( X ) District Justice transcript of judgment in civil action in the amoun
of $ 1689„76 , plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle operator
license wi?l be suspended by the Pennsylvania Department
of TranspoYtation. By: _J44 -
Pr onota
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 487326 / 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
(This Notice is given in'. accordance with Pa. R.C.P. 236.)
DJNTC/PANOJ W&A FILE'!NO. 123831739
i
4940
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
GREAT SENECA FINANCIAL CORP.,
A MARYLAND CORPORATION, ASSIGNEE
Plaintiff
Vs.
BRIAN R WATERS
826 N MARKET ST
DUNCANNON PA 17020
Defendant(s)
14hSlc?/s ?
NO. 06841
COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
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.
SS# 199 50 6283
ORALEX/PAWRIT W&A FILE NO. 123831739
4938
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - BRIAN K WATERS
826 N MARKET ST
DUNCANNON PA 17020
SS# 199 50 6283
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 536553281 with a balance of $984.30 at time served. The account is
held individually.
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.
account 536558281 is a direct deposit account.
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent
time, state whether or not the Defendant(s) maintains any safe deposit box of
boxes. If so, include the identification 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 whethe
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) whic
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. 123831739
4939
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, dit
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 cause prior to
service, none of which were at the direction of Camerce 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
Amy F. Doyle #87062 / Dania V lfson
Philip C. Warholic x/86341 /
Commerce Bank David R. Galloway $87326 / n M. ippie
801 Paxton Street Ronald M. Abramson #94266 / Ronald S. Canter #94
irrisbUrg, PA 17111 Bruce H. Cherkis #18837
7 -412-6134 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff
4c'o Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
Date: 6
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., NO. 06841
A MARYLAND CORPORATION, ASSIGNEE
Plaintiff
vs. CIVIL ACTION-LAW
BRIAN R WATERS
826 N MARKET ST
DUNCANNON PA 17020
Defendant(s) nn
al.i.suXeZ l0
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.
SS# 199 50 6283
W&A FILE NO. 123831739
.`4938
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - BRIAN K WATERS
826 N MARKET ST
DUNCANNON PA 17020
SS# 199 50 6283
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 536558281 with a balance of $984.30 at
time served. The account is held individually. Direct deposit
of $932.88 had been made.8/25/06. The account has a balance
of $1897.18.
LA. 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.
Yes, account 536558281 is a direct deposit account.
2. SAFE DEPOSIT BOXES: At the time you were served or at any subsequent
time, state whether or not the Defendant(s) maintains any safe deposit box of
boxes. If so, include the identification 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.
t
4939
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,
cuatody,'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, did
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, 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
Amy F. Doyle #87062 / Dania Wolfson
Philip C. Warholic #86341 /
Commerce Bank David R. Galloway #'87326 / i yn M. Chipple
01 Paxton Street Ronald M. Abramson #94266 / Ronald S. Canter #9400(
H sburg, PA 1 177111 Bruce H. Cherkis #18837
7 -41 -( WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff 134 Attorneys in the Practice of Debt Collection
a? 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
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4937
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
GREAT SENECA FINANCIAL CORP., IN THE COURT OF COMMON PLEAS OF
A MARYLAND CORPORATION, ASSIGNEE CUMBERLAND COUNTY, PENNSYLVANIA
OF MRC RECEIVABLES CORP.,
ASSIGNEE OF BANK FIRST
P.O. BOX 1651
ROCKVILLE, MD 20849
Plaintiff
VS. JUDGMENT NO. 06841
BRIAN K WATERS
826 N MARKET ST .
DUNCANNON PA 17020 PRAECIPE FOR WRIT OF EXECUTION
(MONEY JUDGMENT)
Defendant (s)
To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER.
(1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania;
(2) against, BRIAN K WATERS
826 N MARKET ST
DUNCANNON PA 17020
. Defendant (s) ;
(3) and against, COMMERCE BANK
20 NOBLE BLVD
CARLISLE PA 170i3-4119 Garnishee(s);
(4) and index this writ
(a) against, BRIAN K WATERS
, 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) *** GARNISH ONLY ***
You are directed to attach the property of the Defendant(s) not levied upon in the
possession of COMMERCE BANK
20 NOBLE BLVD
CARLISLE PA 17013-4119
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 05/12/2005
At an interest rate of 6% per year
Dated:
$ 994.76
To Be Determined
Total $ 994.76 Plus costs & interest
Amy F. Doyle #87062 / ionn1 niel F. Wolfson X20617
Philip C. Warholic #86341 /
David R. Galloway #87326 / yn M. lpple 8
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 Trindlp Road 3rd F1nnr Camn Hi11 Pd 17!111 / (71
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WRIT OF EXECUTION and/or ATTACHMENT
.01%
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
MARYLAND CORPORATION, ASSIGNEE OF MRC RECEIVABLES CORP., ASSIGNEE OF
BANK FIRST, Plaintiff (s)
From BRIAN K. WATERS, 826 N MARKET ST., DUNCANNON, PA 17020
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of COMMERCE BANK, 20 NOBLE BLVD., CARLISLE, PA 17013-4119 -- 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.
NO 06-841 Civil
CIVIL ACTION - LAW
Amount Due $994.76 L.L. $.50
Interest FROM 05/12/05 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm % Due Prothy $1.00
Atty Paid $37.25 Other Costs
Plaintiff Paid
Date: AUGUST 1, 2006
CURTIS R. LONG
Prothonota
(Seal) BY
4 f, a g, svrx4c?
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD, 3RD FLOOR
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87737
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP
Plaintiff NO. 06841
VS.
BRIAN WATERS
VS.
COMMERCE BANK
Defendant(s)
Garnishee(s)
CIVIL ACTION - LAW
PRAECIPE TO DISSOLVE GARNISHMENT
To the Prothonotary:
Please release the Lis Pendes on a Judgment filed against Commerce Bank, garnishee in the
above -entitled case and mark the Judgment against the garnishee as withdrawn.
Dated: Lt, Respectfully Submitted,
P" ? 4
Amy F. Doyle #8742
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 17011
(717) 303-6700
W&A File No. 123831739
w
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75
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., No. 06841
A MARYLAND CORPORATION, ASSIGNEE
OF MRC RECEIVABLES CORP.,
ASSIGNEE OF BANK FIRST
P.O. BOX 1651
ROCKVILLE, MD 20849
Plaintiff
VS.
BRIAN K WATERS I .
826 N MARKET ST
DUNCANNON PA 17020
Defendant(s)
i
PRAECIPE TO S TTLE AND SATISFY
PLEASE MARK THE ABOVE-CAPTIONED ANION AS SETTLED, SATISFIED AND DISCONTINUED.
Respectfully submitted,
By:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
P 6341 / Andrew C. Spears #87737
David Gallowa #873 Tonilyn M. Chippie #87852
na M. Abramson / 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
cc:
PAPR4/PA176A W&A FILE NO. 123831739
-? E ..:.
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-00841 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GREAT SENECA FINANCIAL CORP
VS
WATERS BRIAN
And now RICHARD SMITH Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:25 Hours, on the 10th day of August , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
WATERS BRIAN K , in the
hands, possession, or control of the within named Garnishee
COMMERCE BANK 20 NOBLE BLVD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BECKY MOORE (ASST 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 Her .
Sheriff's Costs: So answers:
Docketing .00
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
00 V 9_
08/11/2006
Sworn and Subscribed to
before me this day of By
put Sheriff
A.D
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-841 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A
MARYLAND CORPORATION, ASSIGNEE OF MRC RECEIVABLES CORP., ASSIGNEE OF
BANK FIRST, Plaintiff (s)
From BRIAN K. WATERS, 826 N MARKET ST., DUNCANNON, PA 17020
(1) You are directed to levy upon the property of the defendant (s)and to sell .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of COMMERCE BANK, 20 NOBLE BLVD., CARLISLE, PA 17013-4119 -- 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 $994.76 L.L. $.50
Interest FROM 05/12/05 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm % Due Prothy $1.00
Atty Paid $37.25 Other Costs
Plaintiff Paid
Date: AUGUST 1, 2006
CURTIS R. LONG
Prothonota
(Seal) By:
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD, 3'm FLOOR
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87737
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff s Costs: Advance Costs: 150.00
Sheriff s Costs 85.36
Docketing 18.00 64.64
Poundage 1.68
Advertising
Law Library .50
Prothonotary 1.00 Refunded to Atty on 04/27/07
Mileage 4.40
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage .78
Garnishee 99^00
TOTAL 85.36 ?/ sJa v?oy ?., So Answers;
..e lap
R. Thomas Kline, Sheriff
By
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