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.
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Prothono ary/Clerk, iv41 ivision
By:
Deputy
PRAEDJ/PANOJ W&A FILE NO. 139906911
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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
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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
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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
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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
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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
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP. No.
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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
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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.
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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
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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
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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 ?'?
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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
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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
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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