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HomeMy WebLinkAbout06-23814347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. C101 LI-7?Z11Y 210 SYLVAN AVENUE 1 ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. KRISTIE YARLETT Defendant(s) PRAECIPE FOR JUDGMENT Mr./Ms. Clerk: Please enter Judgment in favor of Plaintiff and against Defendant(s), KRISTIE YARLETT and pursuant to the District Justice Transcript. ( X ) Amount due $ Less credits $ TOTAL $ 3701.71 3701.71 , 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 oc Rcc:>rd. E" ? - - - DATE: Signature: Amy F. oyle 87062 / Daniel F. Wolfson /20617 Philip C. Warho c #86341 / Andrew C. Spears /87737 David R. Gallow {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 NOW, 20Q(o , JUDGMENT IS `ENTERED AS VE. Prothon ary/Clerk evil Division By: Deputy .? -_ -, 's,, COMMONWEALTH OF PENNSYLVANIA *Cnl INTY OF- CUMBERLAND Mag. Dist. No.'. 09-2-01 MDJ Name: Hon. PAULA P. CORREAL Address. 1 COURTHOUSE SQ CARLISLE, PA Telephone: (717) 240-6564 17013-0000 ATTORNEY DEF PRIVATE : AMY F. DOYLE WOLPOFF & ABRAM 4660 TRIHDLE RD THIRD FL CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment:' ® Judgment was entered for: NOTICE OF J MENT/TRANSCRIPT DG ?+ CIVIL LASE PLAINTIFF: NAME and ADDRESS rPALISADES COLLECTION, L.L.C. 4660 TRINDLE ROAD 3RD FLOOR LCAMP HILL, PA 17011 J vs. DEFENDANT: NAME and ADDRESS rY-ARLETT, KRISTIE 52 RECENCY WOODS H CARLISLE, PA 17013 L J Docket No.: CV-0000398-05 Date Filed: 9/13/05 (Name) PAr TaIii r--ntr RL'TTO77 L_L.C Judgment was entered against: (Name)_yART.wTT„ irg TSTT$ in the amount of$ a,7n1.71 on Defendants are jointly and severally liable. E] Damages will be assessed on: 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) 12 /1 o nG (Date & Time) Amount of Judgment $ Judgment Costs $ Interest on Judgment $ Attorney Fees $ Post Judgment Credits $ I 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 JUDGMENT/TRANSCRIPT 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, F : SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. I: f Date Me District Judge I certif that is is a true nd c r t t coy e r of the ceedings contaifijA the judgment. - y 2 Date IVlagi6terial District Judge My commission expires first Monday of January, 2006 -A? _` AOPC 315-05 DATE PRINTED: 12/19/05 1:36:21 P?1414 i?qO / ? ? ? _ ? i --i ? ??? lJ II 'f'- T' N `... ?- -" ..J 1 t-_' t' i I ?. ?? )i' ?' <_ 4346 IN THE COURT OF COMMON PLEAS OF CUMBERLANNDCOUNTY, PENNSYLVANIA PALISADES COLLECTION LLC No. - oZ3p? Cw 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff Vs. CIVIL ACTION - LAW KRISTIE YARLETT Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I, hereby certify that the precise residence of Plaintiff is: PALISADES COLLECTION LLC ASSIGNEE OF PROVIDIAN NATIONAL BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 and certify that the last known address of the within Defendant(s) is: KRISTIE YARLETT 52 REGENCY WOODS N CARLISLE PA 17013 Amy F.'Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warh lic 086341 / Andrew C. Spears #87737 David R. Gallo ay #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 4345 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. KRISTIE YARLETT Defendant(s) No. Ob - a.3?1 CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose that I am the Attorney for the Plaintiff in the above-captioned matter, the best of my knowledge, information and belief Defendant, KRISTIE YARLETT , above-named, is over 21 years of age; known to reside at 52 REGENCY WOODS N CARLISLE PA 17013 and say and that to is last 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 "iotarial Seal Kimberly L. Eiser,hauer, Notary Public Hampden Twp., Curnberland County •bW Commission E1:pires Nov, 17,200q Maniber, Penruylvanla 4ssociation of Notaries Amy r. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Wa olic #86341 J Andrew C. Spears #87737 David R. Gal oway #87326 / Tonilyn M. Chippie #87852 Ronald M. Abramson #94266 J 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 SWORN and SUBSCRIBED to before me this 0 day of 1Z('?, , 200-P. Notary Public .1 ?? i ?. __ 4344 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC NO. OL - Z?P 1 (2LUIL !v 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS KRISTIE YARLETT 52 REGENCY WOODS N CARLISLE PA 17013 Defendant(s) CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT TO: KRISTIE YARLETT 52 REGENCY WOODS N CARLISLE PA 17013 You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on Qna?l ?? abD 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 $ 3701.71 , plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: Pr honotary i If you have any questions regarding this Notice, please contact the filing party. n I n n I Z Amy F. 3)6yle-- #87062 / D"aniet'F. Wolfson x/20617 Philip C. Warh is #86341 / Andrew C. Spears #87737 David R. Gallo y #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 accordance with Pa. R.C.P. 236.) 1025 7 PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) r 1"' P.R.C.P. 3101 to 3149 PALISADES COLLECTION LLC IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF PROVIDIAN NATIONAL CUMBERLAND COUNTY, PENNSYLVANIA BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS, NJ 07632 Plaintiff VS. KRISTIE YARLETT 3122 RIDGE AVE APT D MACON GA 31204 Defendant (s) JUDGMENT NO. 06-2381 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, KRISTIE YARLETT 3122 RIDGE AVE APT D MACON GA 31204 Defendant (s) ; (3) and against, SOVEREIGN BANK 310 EAST PENN DRIVE ENOLA PA 17025 Garnishee(s); (4) and index this writ (a) against, KRISTIE YARLETT Defendant (s) and (b) against, SOVEREIGN 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 SOVEREIGN BANK 310 EAST PENN DRIVE ENOLA PA 17025 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 12/19/2005 At an interest rate of 6% per year Dated: $ 3701.71 To Be Determined Total $ 3701.71 Plus costs & interest 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 110 n z 4.A -o Tv'k -Go- C a ?o -•3 SLa '? v't, 9? V? 9? t/1 v ? r F-J -r E`er f'T.t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-2381 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION LLC Plaintiff (s) From KRISTIE YARLETT, 3122 RIDGE AVE APT D, MACON, GA, 31204 (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 GARNISHEE(S) as follows: SOVEREIGN BANK, 310 EAST PENN DRIVE, ENOLA, PA 17025 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. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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$3701.71 L.L. $.50 Interest Atty's Comm % Due Prothy $1.00 Atty Paid $ 37.25 Other Costs Plaintiff Paid Date: January 29, 2007 Curti . Long, Proth ry (Seal) By: Deputy REQUESTING PARTY: Name Andrew C. Spears, Esquire Address: WOLPOFF & ABRANSON, LLP, 4660 TRINDLE RD, 3'm FLR., CAMP HILL, PA 17011 Attorney for: PALISADES COLLECTION LLC Telephone: 717-303-6700 Supreme Court ID No. 87737 n6LO&r, 4V D6 - 3?l PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - KRISTIE YARLETT 3122 RIDGE AVE APT D MACON GA 31204 SS# XXX-XX-7871 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. SEE ATTACHED VERIFICATION 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. ANY DIRECT DEPOSIT AGREEMENTS FOR AUTOMATED DEPOSITS ARE BETWEEN OUR CUSTOMER AND THE ORIGINATOR OF THESE DEPOSITS, SOVEREIGN BANK IS NOT A PARTY. 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 o: 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 amoun' 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. NONE 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. NONE 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). NO ORALE2/PAWRIT W&A FILE NO. 141419409 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. NO 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). NO 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, di 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. NO 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- X57062 / Daniel F. Wolfson #2061 Philip C. Warholic #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 Date: 12 V Account No. Account Holder: 2601764279 Kristie L. Yarlett Scott M. Becker 31 South Lancaster St. Annville, PA 17003 VERIFICATION Balance: $1,068.52 I, Camille Neuwinger, Process Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: ( -77V Camille Neuwinger COP Lead Specialist t7 co r?) 7 a4. _t THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Palisades Collection LLC assignee of Providian National IN RE: Vs. Kristie Yarlett CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption. I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Andrew C. Spears, Esquire Wolpoff & Abramson LLP 4660 Trindle Rd. 3`d Floor Camp Hill, PA 17011 Service by certified mail addressed as follows: Kristie L Yarlett 31 South Lancaster St. Annville, Pa 17003 SignatureafPtIr'son Filing C. Neuwinger, COP Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrissey Boulevard Boston, MA 02125 February 23, 2007 ra ?? . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 06-2381 vs. KRISTIE YARLETT Defendant vs. SOVEREIGN BANK Garnishee Garnishee: SOVEREIGN BANK 310 EAST PENN DR ENOLA PA 17025 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Bank, in the amount of $534.26, as admitted in the answer to Interrogatories to be in the possession of Garnishee. The amount of the judgment together with interest and costs of the Please enter judgment in favor of the Plaintiff and against the Garnishee, Sovereign CIVIL ACTION - LAW Plaintiff against the Defendant is $2,835.89. Dated: 5k-1[0-1 Respectfully Submitted, 4-- Amy ogle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Tonilyn M. Chippie #87852 David R. Galloway #87326 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Ronald M. Abramson #94266 / Ronald S. Canter #94000 WOLPOFF & ABRAMSON, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 / (717) 303-6700 W&A File No. 141419409 cc: KRISTIE YARLETT 31 S LANCASTER ST ANNVILLE PA 17003 sCB Sovereign BankM Court Ordered Processing MA1 MB3-02-10 P.O. Box 841005 Boston, MA 02284 February 23, 2007 Email: CNeuwing@Sovereignbank.com Prothonotary's Office Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Re: Palisades Collection LLC assignee of Providian Vs. Kristie Yarlett No. 06-2381 Dear Sir/Madam: Enclosed is Sovereign Bank's Answers to Interrogatories in Attachment and an original and one copy of a Certificate of Service. Please file the originals in your office and return the time-stamped copy of the Certificate in the enclosed return envelope. By copy of this letter we are serving those partied listed on the Certificate of Service with a set of Answers. We are also serving the Defendant with a copy of the Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order, and Claim for Exemption. Very truly s, Camille tu ' er COP Lead Specialist 617-533-1146 Fax 617-533-1188 CN/s Enclosures PC: Andrew C. Spears, Esquire (w/enclosures) Kristie Yarlett (w/enclosures, certified mail) 4 10258 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - KRISTIE YARLETT 3122 RIDGE AVE APT D MACON GA 31204 SS# XXX-XX-7871 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. SEE ATTACHED VERIFICATION 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. ANY DIRECT DEPOSIT AGREEMENTS FOR AUTOMATED DEPOSITS ARE BETWEEN OUR CUSTOMER AND THE ORIGINATOR OF THESE DEPOSITS, SOVEREIGN BANK IS NOT A PARTY. 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. NONE 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. NONE 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) whit] are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset(s). NO ORALE2/PAWRIT W&A FILE NO. 141419409 10259 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. NO 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). NO 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, 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. NO 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`' '18T062 / Daniel F. Wolfson #2061 Philip C. Warholic #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 Date: A-n? 01 Account No. Account Holder: 2601764279 Kristie L. Yarlett Scott M. Becker 31 South Lancaster St. Annville, PA 17003 VERIFICATION Balance: $1,068.52 I, Camille Neuwinger, Process Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unworn falsification to authorities. Sovereign Bank By: (6?/ lorv Camille Neuwinger COP Lead Specialist THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Palisades Collection LLC assignee of Providian National IN RE: Vs. Kristie Yarlett CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption. I have served a copy thereof on each of the following persons in the manner indicated below: Service by f rst class mail addressed as follows: Andrew C. Spears, Esquire Wolpoff & Abramson LLP 4660 Trindle Rd. 3rd Floor Camp Hill, PA 17011 Service by certified mail addressed as follows: Kristie L Yarlett 31 South Lancaster St. Annville, Pa 17003 Signature rson Filing C. Neuwinger, COP Lead Specialist Sovereign Bank MAI M133-02-10 2 Morrissey Boulevard Boston, MA 02125 February 23, 2007 \ 1 N J r'? ? C? _ u ?t - ? -?-? --a ? T G c ? ? ? ? ? t ??;_ ? C ? ?; l^ ?.:? ? ? :..: ? ? ? ? ?? ? ?? SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-02381 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS YARLETT KRISTIE And now JESSICA HERMANSEN ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:46 Hours, on the 12th day of February-, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , YARLETT KRISTIE hands, possession, or control of the within named Garnishee SOVEREIGN BANK 310 EAST PENN DRIVE ENOLA, PA 17025 Cumberland County, Pennsylvania, by handing to GIZEM LESPERANCE (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 Sworn and Subscribed to , in the true and made So an w r .00 .00 .00 R. Thomas Kline 00 Sheriff of Cumberland County 0000/}k"o 02/13/2OQ7 before me this day of By A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 06-2381 vs. KRISTIE YARLETT Defendant CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE To the Prothonotary: Kindly mark the judgment entered against the Garnishee, Sovereign Bank, in the above matter, satisfied upon payment of your costs only. Amy F. Doyle #87062 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 W&A File No. 141419409 0 c C3 C?`? 's7 ?iD lA . t ` t"r W CO f n c C? d'dly- R. Thomas Kline, Sheriff, who li rig ing to law, states this Writ is returned ABANDONED, no action'takmii sit months. Sheriff's Costs: 2001 FES - ' p Lk6vance Costs: 150.00 Sheriffs Costs 93.54 Docketing 18.00 56.46 Poundage 1.84 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 04/30/08 Mileage 13.20 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee 9.00 C '`" TOTAL 93.54 ? So Answers, R. 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