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