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HomeMy WebLinkAbout06-1293458 IN THE COURT OF COMMON D PLEAS OF CUMBERLAN COUNTY, PENNSYLVANIA ? ?1 t?l - NO ?293 l}/ULI GREAT SENECA FINANCIAL CORP., o . P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. LOUISE E LYNCH Defendant(s) Mr./Ms. Clerk: PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), LOUISE E LYNCH pursuant to the District Justice Transcript. ( X ) Amount due $ Less credits $ TOTAL $ 3834.67 3834.67 , 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: b( Signature: 12 fd,,? Amy F, A?le____ #87062 / Daniel F. Wolfson #20611 ?y Philip Warhol _86341 / Andrew C. Spears #87737 David R. Gafl6 a 1/87326 / Tonilyn M. Chippie /87852 Ronald M. Abramson x/94266 / Ronald S. Canter #94000 Bruce H. Cherkis x/18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 NOW, 20i:)l JUDGMENT IS ENTERED AS MOVE. 1 Protho otar er Civ' Division By: Deputy COMMONWEALTH OF PENNSYLVANIA rnI Ill nc CUMBBRI AM Mag- Dist No-: 09-3-01 NOTICE OF 16DG?6NY/TRANSCRIPT PLAINTIFF CIVIL CASE fJAMFa (ADDRESS FOREAT SENECA FINANCIAL CORP 267 EAST MARKET ST C/O WOLPOFF & ABRAMSON LYORK, PA 17403 J vs. DEFENDANT: NAMi-ai.d ADDRESS FLYNCH, LOUISE E, ET AL,4- 30 E ORANGE ST SHIPPENSBURG, PA 17257 L J Docket No.: CV-0000157-05 Date Filed: 5/17/05 MDJ Name: Hon. HAROLD H. BENDER Address: 35 19 ORANGE ST SHIPPENSBURG, PA Telephone: (7171 532-7676 17257-0361 GREAT SENECA FINANCIAL CORP 267 EAST MARKET ST C/O WOLPOFF & ABRAMSON YORK, PA 17403 THIS IS TO NOTIFY YOU THAT: Judgment: ® Judgment was entered for: (Name) r--RlPAT agirl trTili rraT. Ill ® Judgment was entered against: (Name) T.YMCB,LOIIISB B In the amount of $ 10 Ill on: ? Defendants are jointly and severally liable. ? Damages will be assessed on: F1 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 of Judgment) #;-/D8/Ds (Date & Time) 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 PROTHONOTARYICLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTTRANSCRIPT 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. r(J 'C J? S Date /7Q•ro k? Magisterial District Judge I certify that this is a true and correct copy of the cord of the proceedings containing the judgment. "/1'(2S, Date ?u' ^-G--_- MagisterialDlstri udge My commission expires first Monday of January, 2006. SEAL 1-62?q v? AOPC 315-05 DATE PRINTED: 6108105 11:31:55 AM ??? ?? ?-- _ ? ???? ?? ?? 1 ?, -?? `? 0 ?' 457 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 12'D P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff vs LOUISE E LYNCH Defendant(s) CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF DISCOVER BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: LOUISE E LYNCH 30 E ORANGE ST SHIPPENSBURG PA 17257 Amv FF._'Doyle#87062 / Daniel F. Wolfson x/20617 Philip C. Warhol #86341 / Andrew C. Spears #87737 David R. Galloway x/87326 / Tonilyn M. Chippie x/87852 Ronald M. Abramson x/94266 / Ronald S. Canter #94000 Bruce H. Cherkis x/18837 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 (717) 303-6700 455 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. 0(? - ?z (2t0L S'Z-,_;j P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. CIVIL ACTION - LAW LOUISE E LYNCH 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, LOUISE E LYNCH , above-named, is over 21 years of age; is last known to reside at 30 E ORANGE ST SHIPPENSBURG PA 17257 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. Any F. Doyle #87062 / Daniel-F.'Wolfson #2061", Philip C._ Warh lic #86341 / Andrew C. Spears #87731 David R. Galloway /87326 / Tonilyn M. Chippie8785i Ronald H. Abramson /94266 / Ronald S. Canter #9400( Bruce H. Cherkis #18837 otetc"'I WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff mbr-.rlvlFisenna.,p hiaryPublic Attorneys in the Practice of Debt Collection pi+en Tvp 'umberiaud County 4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011 T r, t%' (717) 303-6700 SWORN and SUBSCRIBED to before me this 2?_ day of ksk \ 20k. Notary Public 455 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. O(o P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. LOUISE E LYNCH Defendant(s) CIVIL ACTION - LAW 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, LOUISE E LYNCH , above-named, is over 21 years of age; is last known to reside at 30 E ORANGE ST SHIPPENSBURG PA 17257 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. U .h,vi: V h'cALT-i [? E'n d`>Yi s ANA A I r:.mberly L Eisenna-per, Notary Public rV lpden Tv C 1 rberiaud Co my t n <r v. 1; ? ? Amy. F_Doyle #87062 / Daniel F. 'Wolfson x/2061: Philip C._ Warh ME #86341 / Andrew C. Spears #8773: David R. Galloway //87326 / Tonilyn M. Chippie /8785; Ronald M. Abramson #94266 / Ronald S. Canter /9400( 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 SWORN and SUBSCRIBED to before me this ZZ- day of t 1C l 20Ckbl C No ary Public ?:, 454 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., NO. W// - IdQ3 6ULC? P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. LOUISE E LYNCH 30 E ORANGE ST SHIPPENSBURG PA 17257 Defendant (s) CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: LOUISE E LYNCH 30 E ORANGE ST SHIPPENSBURG PA 17257 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on rnA1U J_ 17 2-iOi ( 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 $ 3834.67 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by t he Pennsylvania Department of Transportation. By: tL - Pro '-f honotar If you have any questions regarding this Notice, please contact the filing party. fl, Oj? l iz_ A>t? F. Do$?le #87062 / Daniel F.-Wolfson x/20617 Philip C. Warho c #86341 / Andrew C. Spears x/87737 David R. Gallows #87326 / Tonilyn M. Chippie x/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.) 9333 AV PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF DISCOVER BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V8. JUDGMENT NO. 06-1293 LOUISE E LYNCH 30 E ORANGE ST SHIPPENSBURG PA 17257 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: PLEASE ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND COUNTY, Pennsylvania; (2) against, LOUISE E LYNCH 30 E ORANGE ST SHIPPENSBURG PA 17257 , Defendant(s); (3) and against, ORRSTOWN BANK 121 LURGAN AVE SHIPPENSBURG PA 17257-1600 Garnishee(s); (4) and index this writ (a) against, LOUISE E LYNCH Defendant(s) and (b) against, ORRSTOWN 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 ORRSTOWN BANK 121 LURGAN AVE SHIPPENSBURG PA 17257-1600 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 $ 3834.67 Interest from 06/08/2005 To Be Determined At an interest rate of 62 per year i Total $ 3834.67 Plus costs & interest Dated: 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 Tr;ndla Rnad_ 3rd Flnnr_ Came Hilt PA 17n11 / -f- fJ t tAf r? v( Cv e c ? . tom, ^f f_J CJ G) z GJ ? J p-ri 3^`7 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N006-1293 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP., A MARYLAND CORPORATION, ASSIGNEE OF RECOVERY PARTNERS, L.L.C., ASSIGNEE OF DISCOVER BANK, Plaintiff (s) From LOUISE E. LYNCH, 30 E. ORANGE ST., SHIPPENSBURG, PA 17257 (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 ORRSTOWN BANK, 121 LURGAN AVE, SHIPPENSBURG, PA 17257-1600 - 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 $3834.67 L.L. $.50 Interest FROM 6/8/05 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Any Paid $37.25 Plaintiff Paid Date: MAY 31, 2006 Due Prothy $1.00 Other Costs ZTIS&R. LONG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, 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. 86341 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL Plaintiff NO. 06-1293 VS. LOUISE E LYNCH Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Orrstown Bank, discontinued, upon payment of your costs only. Submitted, Dated: Z !? #87062 Daniel F. olfson #20617 Philip C. arholic #86341 Andrew C. Spears #87737 David R. Galloway #87326 Tonilyn M. Chippie #87852 Sarah E.Ehasz #86469 Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 Ronald S. Canter #94000 Bruce H. Cherkis #18837 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., 3 d Floor Camp Hill, PA 17011 (717) 303-6700 W&A File No. 132048268 7?3 ? ? ? P ? G ?-, °.v ? ,__ ? h ?. -? ? , SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01293 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS LYNCH LOUISE E And now RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0008:43 Hours, on the 9th day of June , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LYNCH LOUISE E in the hands, possession, or control of the within named Garnishee ORRSTOWN BANK 22 S. HANOVER ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JACKIE JUMPER (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . true and made Sheriff's Costs: So answer- Docketing .00 ? P Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 n Of rl/030` 06/09/2006 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D Great Seneca Financial Corp. Vs Louise E. Lynch Writ of Execution Docket No. 2006-1293 Civil Term ,l. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. No action has been taken in the last six months. Sheriff's Costs Docketing $18.00 Surcharge $30.00 Levy $20.00 Mileage $ 5.00 Poundage $ 1.67 Prothonotary $ 1.50 Garnishee $ 9.00 Total $85.17 ,/ ii/.zolOl ?- So Answers: e aevvwmwoo? R. Thomas Kline, Sheriff BY MLL Sergeai t I-' c k .7.2 9S) gr_,. 2 33 ?3`f