Loading...
HomeMy WebLinkAbout06-1943IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA y GREAT SENECA FINANCIAL CORP., N0. 0(o - 167ZIJ G( UL ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. MARY E OBRIEN Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), MARY E OBRIEN and pursuant to the District Justice Transcript. ( X ) Amount due $ Less credits $ TOTAL $ 4755.20 4755.20 , 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: Amy F. Doyle //87062 / Daniel. F._Wolfaon //20617 Philip C. Warholic #86341 / (Andrew C. Spears#877733 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, Q, 20JUDGMENT IS/7TERED AS VE. rt - Prothono ary/Clerk, iv41 ivision By: Deputy PRAEDJ/PANOJ W&A FILE NO. 139906911 " r_? { j ` 1 ? ?? _. ? ? ._ ^. i.:; COMMONWEALTH OF PENNSYLVANIA nn] rniTV nC- CUMBERLAND 09-1-02 MDJ Name: Hon. ROBERT V. MANLOVE Address: 1901 STATE ST CAMP HILL, PA Telephone. (717 ) 761-0583 17011-0000 GREAT SENECA FINANCIAL CORP/CHASE 4660 TRINDLE RD 3RD FL/96WOLPOFF & ABRAMSN CAMP HILL, PA 17011 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE ALAINTIFF: NAME aad ADDRESS rGREAT SENECA FINANCIAL CORP/CHASE 7 4660 TRINDLE RD 3RD FL/%WOLPOFF & ABRAMSN LCAMP HILL, PA 17011 J VS. DEFENDANT: NAMEand ADDNesS rOBRIEN, MARY E 526 S ENOLA RD APT/STE 2 ENOLA, PA 17025 COU01 I ( -J L 12 Docket No.: CV-0000464-05 AD, ML, 4h Date Filed: 9/14/05 ?Y THIS IS TO NOTIFY YOU THAT: Judgment: ® Judgment was entered for: (Name) gRizaT awwra FTNANCTAr CORR ICH ® Judgment was entered against: (Name) nsRTRu, aRr 8 in the amount of $ 4, 7 a5.2 o on: (Date of Judgment) 11114 Ina ? Defendants are jointly and severally liable. E] 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 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 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 SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I 4" Date Magisterial District Judge I ?c( e ' ify {In'Jatt4 tthIS s a ject- alaining the judgment. Dat L Magisterial District Judge My commission expires first Monday of January, 2006. SEAL AOPC 315-05 DATE PRINTED: 11/14/05 12:51:58 PM COMMONWEALTH OF PENNSYLVANIA " -COUNTY OF: CUMBERLAND Mag. Dist. No.: 09-1-02 MDJ Name'. Hon. ROBERT V. MANLOVE Ad"essr 1901 STATE ST CAMP HILL, PA Telephone: (717 ) 761-0583 17011-0000 ATTORNEY FOR PLAINTIFF : ANY F. DOYLE WOLPOFF & ABRAM 4660 TRINDLE RD THIRD FL CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: ® Judgment was entered for: NOTICE OF JUDGMENT/TRANSCRIPT PLAINTIFF: CIVIL CASE NAME and ADDRESS FGREAT SENECA FINANCIAL COHP/CHASE 4660 THIHDLE HD 3RD FL/%WOLPOFF & ABRAMSN LCAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rOBRIEN, MARY E 526 S EHOLA RD APT/STE 2 ENOLA, PA 17025 L J -OS Docket .:CV-0000464 Date Filed: 9/14/05 (Name) r_uuAm agmwrA FTTTAxr TAT. rARPlar ® Judgment was entered against: '( 6e) - ing-rw M"y E in the amount of $ 4, 79r, _ 2n 'on: (%te of Judgment) 11 /14/n5 Defendants are jointly and severally liable. "? 6 (Date & Time) I Damages will be assessed on: l i This case dismissed without prejuc(ice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ ? Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 4,597.86 Judgment Costs $ 157.34 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 4,755.20 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 A D NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE C U T OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date ,:Ma91§t;ehal bistrict Judge I certify that this is atr o veect copJ orripf_tlae prA edttlgs c he )udgment? . Dater',,. ter: 'i Magisterial brStrict Judge My commission expires first Monday of January, 2006. SEAL AOPC 315-05 DATE PRINTED: 11/14/05 12:51:58 PM l 1 l ?. T?l %/? r c7 rl li% IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP., No. C" 'L ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff Vs. CIVIL ACTION - LAW MARY E OBRIEN 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 NEW CENTURY ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 and certify that the last known address of the within Defendant(s) is: MARY E OBRIEN 526 S ENOLA RD //2 ENOLA PA 17025 Amy F. Doyle /87062 / Daniel F. Wolfson #20 Philip C. Warholic #86341 / <Andrew C. Spears #87 David R. Galloway //87326 / Tonilyn M. Chippe-#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 PCRES/PANOJ W&A FILE NO. 139906911 ?-a '?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. No. 0J ?- lvt,L ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff Vs. MARY E OBRIEN 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, MARY E OBRIEN , above-named, is over 21 years of age; is last known to reside at 526 S ENOLA RD //2 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 F. Notarial Seal Kimberly L. Eisenhauer, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries Amy F. Doyle //87062 / Daniel F. Wolfson //20617 Philip C. Warholic //86341 /Andrew C. Spears #83337 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 SWORN and SUBSCRIBED to before me this JLA day of,_, 200(X. -LA Notary'Public PNMAFF/PANOJ W&A FILE NO. 139906911 ?J - 11 ? (_?I[:C '? i. ?.. 4i.: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. NO. CiL i,L? ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff VS. CIVIL ACTION - LAW MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 You are hereby notified That t e following ORDER, DECREE or JUDGMENT has been entered against you on 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 $ 4755.20 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsyl vania Department of Transportation. 7 -? By: . Pro thonotary J If you have any questions regarding this Notice, please contact the filing party. Amy F. Doyle ##7062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 /,Andrew C. Spears #87737 David R. Galloway #87326 1 Tonilyn M. Chippie #87852' Ronald N. 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.) 10237 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, CUMBERLAND COUNTY, PENNSYLVANIA ASSIGNEE OF NEW CENTURY ASSIGNEE OF CHASE MANHATTAN BANK P.O. BOX 1651 ROCKVILLE, MD 20849-1651 Plaintiff . VS. JUDGMENT NO. 06-1943 MARY E OBRIEN 526 S ENOLA RD #2 . 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, MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 , Defendant (s) ; (3) and against, COMMERCE BANK 20 NOBLE BLVD CARLISLE PA 17013-4119 Garnishee(s); (4) and index this writ (a) against, MARY E OBRIEN , 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) 526 S ENOLA RD #2 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 20 NOBLE BLVD CARLISLE PA 17013-4119 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 $ 4755.20 Interest from 11/14/2005 To Be Determined At an interest rate of 6% per year )0-7 Total $ 4755.20 Plus costs & interest Dated: I G "? 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 9?-? C? p k L, SL> m CL . 'J 1t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1943 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP, Plaintiff (s) From MARY E. O'BRIEN, 526 S ENOLA RD #2, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell 526 S ENOLA RD #2, 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 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 GARNISHEE(S) as follows: COMMERCE BANK, 20 NOBLE BLVD, CARLISLE, PA 17013-4119 -- 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. 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 $4755.20 Interest Atty's Comm % Arty Paid $37.25 Plaintiff Paid Date: JANUARY 29, 2007 L.L. $.50 Due Prothy $1.00 Other Costs Curti . Long, Pro y (Seal) By: Deputy REQUESTING PARTY: Name ANDREW C. SPEARS Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, 3RD FLR 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 0 ,. GREAT SENECA FINANCIAL CORP., NO. 06-1943 A MARYLAND CORPORATION, Plaintiff VS. CIVIL ACTION-LAW MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 Defendant (s) Ri1,S[.c?erS 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# XXX-XX-2751 ORALEX/PAWRIT W&A FILE NO. 139906911 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 SS# XXX-XX-2751 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. endant had account 537077380 with a balance of $-1.95 at time served. `Ihe account is held ividually. IA. 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) 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. 139906911 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). I No 8. TRANSFER OF PROPERTY: At any time before or after you were served, dic 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 Cam erce 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 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 immerse Bank 1 Paxton Street David R. Galloway Ronald M. Abramson Bruce H. Cherkis #87326 #94266 #18837 / / Tonilyn M. Chippie Ronald S. Canter #87852 #94000 ;burg, PA 17111 WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaintiff 17 2-6134 Attorneys in the Pr actice o f Debt Collection 4660 Trindle Road, 3rd Flo o r, Camp Hill, PA 17 011 Date (717) 303-6700 Date: l ?'? c) 1 b C 3 7-11 -or" I 1 r3 "T co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREAT SENECA FINANCIAL CORP. Plaintiff vs. MARY E OBRIEN Defendant NO. 06-1943 CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Commerce Bank, discontinued, upon cc payment of your costs only. Dated: W&A File No. 139906911 MARY E OBRIEN 526 S ENOLA RD #2 ENOLA PA 17025 Submitted, Amy F. Doyle 187062 Daniel F. Wolfson #20617 Philip C. Warholic #86341 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 sCB t Xl? R. Thomas Kline, Sheriff, who being duly sworn according to Writ is returned ABANDONED, no law, states this 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 Advance Costs: 150.00 18.00 Sheriffs Costs 12_ 0.47 2.37 29.53 .50 1.00 9.60 40.00 40.00 --9--00- 120.47 ?' Refunded to Atty on 04/30/08 So Answers, R. o as Kline, S ff 0 h Q L??ya X10 8 sy3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1943 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GREAT SENECA FINANCIAL CORP, Plaintiff (s) From MARY E. O'BRIEN, 526 S ENOLA RD #2, ENOLA, PA 17025 (1) You are directed to levy upon the property of the defendant (s)and to sell 526 S ENOLA RD #2, 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 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 GARNISHEE(S) as follows: COMMERCE BANK, 20 NOBLE BLVD, CARLISLE, PA 17013-4119 -- 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. 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 $4755.20 L.L. $.50 Interest Atty's Comm % Atty Paid $37.25 Plaintiff Paid Due Prothy $1.00 Other Costs Date: JANUARY 29, 2007 (Seal) REQUESTING PARTY: Name ANDREW C. SPEARS Address: WOLPOFF & ABRAMSON, LLP Cu . Long, Pro ary By: Deputy 4660 TRINDLE ROAD, 3RD FLR SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01943 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND GREAT SENECA FINANCIAL CORP VS OBRIEN MARY E And now MARK CONKLIN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0010:20 Hours, on the 15th day of February-, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT OBRIEN MARY E hands, possession, or control of the within named Garnishee COMMERCE BANK 20 NOBLE BLVD , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to PAM WILT (ASST. MANAGER personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . Sheriff's Costs: Docketing Service Affidavit Surcharge 5j t) 16'? C),-,/ Sworn and Subscribed to before me this true and made 8o Ia .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 0o 03/26/2007 day of By Deputy Sheriff A.D