HomeMy WebLinkAbout06-2965IN THE COURT OF COMMON PLEAS OF CUMBERLAND/ COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., NO.
Q?'.. "a ILJ
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
Vs.
CINDY M CASSATT
CRAIG A CASSATT
Defendant(s)
Mr./MS. Clerk
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and gainst Defendant(s),
CINDY M CASSATT and CRAIG A CASSATT
pursuant to the District Justice Transcript.
( X ) Amount due $ 7391.16
Less credits $ 630.00 I
TOTAL $ 6761.16 , plu$ 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 cal ulable as a sum certain fro
the complaint.
( X ) Pursuant to Pa.R.C.P. 237 (Notice of Pra cipe for final judgment or
decree), I certify that a copy of this praecipe has b en mailed to each other par
who has appeared in the action or to his/her Attorney of Record.
DATE: /??iz4 _ Signature:
NOW, 206, JU
PRAEDJ/PANOJ W&A FILE NO. 136624409
Amy F. Doyle #87062 / Daniel'F. Wolfs
Philip C. W hol?c #86341 / Andrew C. Spear
David R. Gal owa #87326 / Tonilyn M. Chip
Ronald M. Abrams n #94266 / Ronald S. Cante
Bruce H. Cherkis #18837
WOLPOFF & ABRAMS N, L.L.P. / Counsel for P1
Attorneys in the Practice of Debt Collectio
4660 Trindle Road, 3rd Floor, Camp Hill, PA
(717) 303-6700
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CiAWERLAi® NOTICE OF JUDGMENT/TRANSCRIPT
- CIVIL CASE
Mag. Dist No PLAINTIFF: NAME and ADDRESS
09-a,-o1 ?GMMT SMOCK FIMNCIAL CORP
MDJ Nam¢ Mon 4660 TRII DLE ROAD
PAULA P.. CORREAL $iPDLPOFF?ARAILSON,21RD FLR
Atltlfeb5' 2260 SPRIT d RD' SIIITE S3 LSA HILL PA 17011 _j
CARLISLE: PA
@; s ?. _ . :VS• ?q
Ir ^x. 77`--'
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GRRAT.'8Z=CA;FIHA3512IAL CORP
4660 TRUNDLE ROAD Docket No.: CV-0000016-06
%WOLPO77iARAH9ON,3RD FLR Date Filed: 2/01/06
4 CARP HILL, PA 17011
THIS IS T NOTIFY YOU THAT:
Q Judgment'was entered for: (Name) MiElko r gi mmemk rIyAjSCTXT. CORP
I
0 Judgment was entered against: (Name) oxag aFT, emaxra a
i
in the amount of $ 7, -4 *1 _ T s on:
(Date of Judgment) al/n6/n&
? Defendants are jointly and severally liable. (Date Time)
? partfages`ill be assessed
? Arno nt of Judgment $„ 7'.260..66
m -'
Judg gent Costs $ 130•.50
Inter ston Judgment $ .00
+ This case dismissed without prejudice.
0
Atto ey fees $ .0
6
Total $ 7,391.1
Amount of Judgment Subject to
?
Attachment/42 Pa.C.S. § 8127 $ Post,Iudgment Credits $
i, Portion of Judgment for physical Post Judgment Costs $
damages arising out of residential
lease $ Certified Judgment Total $
. YP?HAS'TH6?HIG T „PEAL_, WITHIN: TN O JU T YF GANO?TIGE„w„?
PEAL WITH THE PROT 'M OTARYICLERX DIP THE COURT OF COMMON PLEAS, CIVI ` DIVISION. YOU
OF AP
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTFrRANSCRIPT FORM WITH YOUR OTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGIS RIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON P AS, ALL FURTHER PROCESS MUST
COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSU D BY THE MAGISTERIAL DISTRICT JUDGE.
UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE I RESTED IN THE JUDGMENT MAY FILE
A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF E JUDGMENT DE 9 PAYS IN
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SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT.
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t Certify thal4this is a true r e copy of fn" _
a eedings" ? mg the jucfgMent.
Date Magisterial District Judge
My commission expires first Monday of January, 2012 . SEAL
AoPCaIS-os DATE PRINTED: 3/07/06 11:16:43 AK
? COWQNWE#LTH OF*,PENNSYLVa IA NOTICE OF JUDGMENTAA?LRIPT
COUNTYOF: CMWEkLA= CIVIL CASE
Mag. Dist No PLAINTIFF: AM anIAOD4lES8
09-2-O1 "TOMMT BZIW& FIS]tz CORD
MDJ N9fael ?IFy1.m'F °eMML: .lw+. „" ., ,'.. ; 4660 TRINDLH ROAD ....----
P %V0LP0Fr"RAl[SOK, 3RD VIA
A.°d 21 ?tIHti "RD'4 avITE 63 LCAHP HILL, PA 17011 J
CARLISLE, -PA VS.
DEFENDANT: NAME and ADDRESS
Tale.pnaa (711) 118-5250 17013-0000 rCASSATT• IHDY c; ET AT
135 ANY D:IVS
ATTORNEY'POR PLAINTIFF s CARLISLE, PA 17013
J
DAVID R. GALLOWAY L
4660 TRINDLE RD Docket No.: CV-0000016-06
CAMP HILL, PA 17011 Date Filed: 2/01/06 Ila
THIS M 1O IN THAT: „ .,
!IGy ^ „?. '„ 56_4
0 Judgment was entered for: (Name) eRy&OP 8> me-,>, rrw>,tmr>,T. ro>Qv
Fil Judgment was entered against: (Nary n>.a)e>,?rr,,T„an_
in the amount of $ 7, A01 '-fa on? -4(Date offludglment) a/e6/D6 R
s
Defendants are jointly and severally liipgle. k / (Da`#e & Time) 'Cl
,r ,
f f)amages will be assessed on; 'i A fno t of Judgment $ 7 X260.66
' Jgdg ent Costs` $ 13-0.50
` - { ter st on Judgment $ .00
this Case dismissed without prejudice. i?ttorrjey Fees $
t -00
i
al
Amount of Judgment Subject to t r 7.391.16
AttachmenU42?Pa:Gh.S. § 8127 $ Post Judgment Credits $
E Portion of Judgment for physical Post Judgment Costs $_--
I damages arising out of residential -- =___== =
lease $ Certified Judgment Total $
ANY PARTY, HAS THE RIGHT TO APPEAL WITHIN 30 DAYSjAp?F}T+ER TH?EMy(E; D{TRY OF JUDG ENT Y FILING A tyN,pO?µT.,L?C..E ?? ?
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/rRANSCRIPT FORM WITH YOUR OTICE OF APPEAL.
i EXCEPT AS. OTHERWISE PROVIDED IN THE RULES OeCIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON P AS, ALL FURTHER PROCESS MUST
M : COME FROM THE COURT OF. COMMON PL SAND NO FURTHER PROCESSMAY BE ISSU D BY 1`FIE:MAGISTERIAL DISTRICT JUDGE
I UNLESS THE JUDGMENT IS ENTERED IN?1'IE COURT OF COMMON PLEAS, ANYONE 1 RESTED IN THE JUDGMENT MAY FILE
U?GE IF.. E JUDGMENT DEBTOR PAYS IN FULL,
A REQUEST FOR ENTRY'OP SATISFACTION WkTH THE MAGISTERIAL DISTRICT,
SETTLES OR OTHERWISE COMPLIES WITH THE JUDGMENT. ,. {,..
F r" '' Uare ? ?dy>,ldlial VIOl1141 JVOI?C
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My commission expires first Monday of January, 2012 t r1,SEAL '
AOPC 315-05 DAT$ PRINTED:. 3/07/06 11:16:16 IN
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., No. OL -:?q/ r
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
VS. CIVIL ACTION - LAW
CINDY M CASSATT
CRAIG A CASSATT III
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 ASCENSION SERVICES,
ASSIGNEE OF KEY BANK, N.A.
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
and certify that the last known address at the within Defendant(e) is:
CINDY M CASSATT CRAIG A CASSATT
135 AMY DR 135 AMY DR
CARLISLE PA 19013 CARLISLE PA 17013
___-_-- 4 __ __?----V- -'---_____--_
Amy F. Doyljr #87062 // Daniel F Wolfson #
Philip C. Wic l#8634 1 Andrew C. Spears #
David R. Gay I#87326 / Tonilyn M. Chippie #
Ronald M. Abramson I#94266 / Ronald S. Canter #
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON,,, L.L.P. / Counsel for Plainti
Attorneys in the Practice of Debt Collection
4660 Trindle Road, '3rd Floor, Camp Hill, PA 1701
(717) 303-6700
PCRES/PANOJ WSA FILE NO. 136624409
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA
FINANCIAL
CORP.,
No. {--
P.O. BOX 1651
ROCKVILLE, MO 20849-1651
Plaintiff
VS. CIVIL ACTION - LAW
CINDY M CASSATT
CRAIG A CASSATT ,
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,
CRAIG A CASSATT above-named, is over 21. years of age; is last
known to reside at 135 AMY DA
CARLISLE PA 17013
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
Notarial Seal
Kimberly L. Eisenhauer, Notary Public
Hampden Twp., Cumberland County
My Commission Expires Nov. 17, 2009
Member, Pennsylvania Aesociatlon of Notedee
Amy F. 41ah ;487062 /Daniel F. Wolfson #
------------
Philip ic #8634 1 / Andrew C. Spears #
David A. Galloway #87326 / Tonilyn M. Chippie 4
Ronald M. Abramson #94266 / Ronald S. Canter #
Bruce H. Cherkis 418837
WOLPOFF 6 ABRAMSON, L.L.P. / Counsel for Plainti
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 1701
(717) 303-6700
SWORN and SUBSCRIBED to before me this
Not
PNMAF2/PANOJ W&A FILE NO. 136614409
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND 'COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., No.
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
vs.
CINDY M CASSATT
CRAIG A CASSATT
Defendant(s)
CIVIL ACTION - LAW
AFFIDAVIT OF NON-MILITARY SERVIC
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-ca tioned matter, and that to
the best of my knowledge, information and belief Defends t,.
CINDY M CASSATT above-named, is over 2 years of age; is last
known to reside at 135 AMY OR
CARLISLE PA 17013
County of CUMBERLAND Pennsylvania; is nodl 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
Notarial Seal
Kimberly L. Elsenhauer, Notary Public
Hampden Twp., Cumberland County
My Commission Expires Nov. 17, 2009
Member, Pennsylvania Association of Notedes
Amy F. Doy a #87062 11.4.V. l F Wolfson #
- - - - - - - - - - - - -
Philip C. Wa holic #86341 / Andrew C. Spears #
David R. Gal oway #87326 / Tonilyn M. Chippie #
Ronald M. Abramson #94266 / Ronald S. Canter #
Bruce H. Cherkis #18837
WOLPOFF & ABRAMSON, L.L.P. / Counsel for Plaint,
Attorneys in the Practice of Debt Collection
4660 Trindle Road, 3rd Floor, Camp Hill, PA 1701
(717) 303-6700
SWORN and SUBSCRIBED to before me this day of
Notary Public
20 _CLU
PNMAFF/PANOJ W&A FILE NO. 136624409
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
0
GREAT SENECA FINANCIAL CORP., NO. Olo _ ?9? IJU?L. ?/LY"I
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
vs.
CIVIL ACTION - LAW
CINDY M CASSATT
CRAIG A CASSATT
135 AMY DR
CARLISLE PA 17013
Defendant(s)
TO: CINDY M CASSATT
NOTICE OF ORDER,
135 AMY DR
CARLISLE PA 17013
i
i
DECREE OR JUD MENT
CRAIG A ASSATT
135 AMY DR
CARLISLE!PA 17013
You are hereby notified that the following ORDER, DEC EE or JUDGMENT has been
entered against you on?_ d/ U in accordance with the provisio
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 $ 6761.16 I plus costs.
( X ) District Justice transcript of judgment in civil action in the amoun
of $ 7391.16 , plus costs.
( ) If not satisfied within sixty (60) days,iyour motor vehicle operator
license will be suspended by the Pennsylnia Department
of Transportation. I t A
By:
If you have any questions
filing party.
this Notice,
the
C
Amy F. le #87062 / iel F. Wolfson #20617
Philip C. Warho c 486341 / drew C. Spears #87737
David R. Gallowaky #87326 / nilyn 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
(This Notice is given in accordance with Pa. R.C.P. 236.)
DJNTC/PANOJ W&A FILE NO. 136624409
Y
23260
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., NO. 062965
A MARYLAND CORPORATION,
Plaintiff
VS. CIVIL ACTION-LAW
CINDY M CASSATT
CRAIG A CASSATT
135 AMY DR
CARLISLE PA 17013
Defendant(s)
k5w 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. GARNISHEEIS 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 b? 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 partjy is
requested, such request includes knowledge of the party's agents,
representatives, and attorneys.
SS# 172 60 8801
ORALEX/PAWRIT W&A FILE NO. 136624409
23258
PLAINTIFF'S INTERROGATORIES 10 GARNISHEE
DEFENDANT(S) - CINDY N CASSATT
CRAIG A CASSATT
135 ANY DR
CARLISLE PA 17013
SS# 172 60 8801 211 52 4563
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. RccA-,-4*r 2-5(Z4
o??? - Gr1i9 CO ++ cmcrrtn9- s 0, DD Dytess
?mR addre?a
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.
. Ac.c, , zt?- 251-343
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 de osit box or
boxes. If so, include the identification number or other designs ion of the
box or boxes. Include a full description of the contents and als 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 an address.
ND
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 whethe
or not there are any encumbrances or liens holders, the present valance of
the encumbrance. State where and when the encumbrances or liensjwas
recorded. If the Defendant(s) owns any personal property jointly with any
person or persons, give namees/ and address.
/V V
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 WSA FILE NO. 136624409
23259
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.
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 net re 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 Defends t(s).
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 De endant(s)
the nature of the property including its value and the interest
of Defendant(s). N t
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 a y person or
place pursuant to your direction or consent. If so, for each De endant(s)
describe the property transferred or delivered including the dat a of
delivery or transfer and state the consideration paid.
10
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, outlinethe exact
amount of any fees due and owing to the garnishee or the attorney for the
garnishee for the preparation of the Answer. NN
Amy F. DoyTe #87U62 / Daniel F. Wolfson #2U
Philip C. Warholic #86341 /'40AW*W C. S srs #87
David R. Galloway #87326 / Tortilyn M. ippie #87
Ronald H. Abramson #94266 / Ronald S. C ter #94
Bruce H. Cherkis #18837 1
WOLPOFF & ABRAMSON, L.L.P. / Counsel fo Plaintiff
Attorneys in the Practice of Debt Colle tion
4660 Trindle Road, 3rd Floor, Camp Hill, PA 17011
(717) 303-6700
Date: I llilu
?: r ca
0
i
23260
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GREAT SENECA FINANCIAL CORP., NO. 062965
A MARYLAND CORPORATION,
Plaintiff
VS. CIVIL ACTION-LAW
CINDY M CASSATT
CRAIG A CASSATT
135 AMY DR
CARLISLE PA 17013
Defendant(s)
INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION
T0;
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# 172 60 8801
ORALEX/PAWRIT W&A FILE NO. 136624409
23258
PLAINTIFF'S INTERROGATORIES TO GARNISHEE
DEFENDANT(S) - CINDY N CASSATT
CRAIG A CASSATT
135 ANY DR
CARLISLE PA 17013
SS# 172 60 8801 211 52 4563
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. P\CC ---4 2-5(P34.3
Primary - CY f !6 COSSQ+f SMM)b - $2;077.2.1
J614 - Cog Casa o&v Me taA3 -4 73929
'I W IA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have
listed above direct deposit accounts? If yes, please state the
i entifica ion iinumbers of //th--ose accounts.
ffcf
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.
N?
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 whethe3
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.
N?
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) whirl
are not disclosed in the preceding Interrogatories. If so, please set forth
all details concerning those asset(s).
1 v?
ORALE2/PAWRIT W&A FILE NO. 1366744nq
23259
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.
A
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).
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). N
8. TRANSFER OF PROPERTY: At any time before or after you were served, dii
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.
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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. 1?
11-N b
Amy F. Doyle #87062 / Daniel F. Wolfson #20
Philip C. Warholic #86341 / Andrew C. Spears #87
David R. Galloway #87326 / Tonilyn N. Chippie #87
Ronald M. 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
Date:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND
GREAT SENECA FINANCIAL CORP., No. 062965
A MARYLAND CORPORATION,
ASSIGNEE OF ASCENSION SERVICES,
ASSIGNEE OF KEY BANK, N.A.
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
vs.
CRAIG A CASSATT
135 AMY DR
CARLISLE PA 17013
COUNTY, PENNSYLVANIA
Defendant(s)
PRAECIPE TO S TTLE AND SATISFY
PLEASE MARK THE ABOVE-CAPTIONED AQTION AS SETTLED, SATISFIED AND DISCONTINUED.
Respectfully submitted,
By:
Any F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. Warh6lic #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
cc:
PAPR4/PA176A W&A FILE NO. 136624409 A
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23257
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 ASCENSION SERVICES,
ASSIGNEE OF KEY BANK, N.A.
P.O. BOX 1651
ROCKVILLE, MD 20849-1651
Plaintiff
VS. JUDGMENT NO. 062965
CINDY M CASSATT .
CRAIG A CASSATT
135 AMY DR
CARLISLE PA 17013 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, CINDY M CASSATT CRAIG A CASSATT
135 AMY DR 135 AMY DR
CARLISLE PA 17013 CARLISLE PA 17013
, Defendant (s) ;
(3) and against, MEMBERS FIRST FCU 1000 BRYN MAWR RD
CARLISLE PA 17013-1588 Garnishee(s);
(4) and index this writ
(a) against, CINDY M CASSATT
CRAIG A CASSATT Defendant(s) and
(b) against, MEMBERS FIRST FCU 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)
135 AMY DR CARLISLE PA 17013
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 MEMBERS FIRST FCU 1000 BRYN MAWR RD
CARLISLE PA 17013-1588
, 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 $ 6761.16
Interest from 03/06/2006 To Be Determined
At an interest rate of 6% per year
Total $ 6761.16 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 Trindle Rnad_ 3rd F1nnr_ Came Hi1I PA 1701tI ?
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO Civil 01-
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 ASCENSION SERVICES, ASSIGNEE OF KEY
BANK, N.A., Plaintiff (s)
From CINDY M. CASSATT AND CRAIG A. CASSATT, 135 AMY DR., CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell 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.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS FIRST FCU, 1000 BRYN MAWR RD., CARLISLE, PA 17013 -1588 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.
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 $6761.16
L.L. $.50
Interest FROM 3/6/06 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $37.25
Plaintiff Paid
Date: JULY 20, 2006
(Seal)
Due Prothy $1.00
Other Costs
C TIS . ONG
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD, 3RD FLOOR
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
4
Supreme Court ID No. 87737
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Great Seneca Financial Corporation
Plaintiff
NO. 062965
vs.
Cindy Cassatt
Craig Cassatt
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, Members First , discontinued, upon
payment of your costs only.
Respectfully Submitted,
ejj
Dated:
Amy F. Doyle #87062
Daniel F. Wolfson #20617
olic #86341
ears #87737
David R. Galloway #87326
&N N
OO
Sar h E asz NW
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. 136624409
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-02965 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GREAT SENECA FINANCIAL CORP
VS
CASSATT CINDY M ET AL
And now RICHARD SMITH Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:27 Hours, on the 2nd day of August , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
CASSATT CINDY M
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DENISE HARMON (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
true
and made
So answers:
.00
r..?'
.00
.00 Thomas Klin ?..-
.00 Sheriff of Cumberland County
.00
.00,E 4;mod`
08/04/2
before me this day of By
A.D
in the
r, . "ft
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-02965 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
GREAT SENECA FINANCIAL CORP
VS
CASSATT CINDY M ET AL
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:27 Hours, on the 2nd day of August , 2006, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT ,
CASSATT CRAIG A in the
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FEDERAL CREDIT UNION
1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DENISE HARMON (ASST. MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
Sworn and Subscribed to
R. Thomas Kline
Sheriff of Cumberland County
00 C
08/04/2006 A
before me this day of
A.D
By
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned Expired.
Sheriff's Costs: Advance Costs: 150.00
Sheriffs Costs 125.36
Docketing 18.00 24.64
Poundage 2.46
Advertising
Law Library .50
Prothonotary 1.00 Refunded to Atty on.02/23/07
Mileage 4.40
Misc.
Surcharge 50.00
Levy 40.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.
TOTAL 125.36
p? e'? So Answers;
R. Thomas Kline, r
ByCI
So qty
C 64
941
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2965 Civil
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 ASCENSION SERVICES, ASSIGNEE OF KEY
BANK, N.A., Plaintiff (s)
From CINDY M. CASSATT AND CRAIG A. CASSATT, 135 AMY DR., CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell 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.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of MEMBERS FIRST FCU, 1000 BRYN MAWR RD., CARLISLE, PA 17013 -1588 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.
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 $6761.16
L.L. $.50
Interest FROM 3/6/06 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm % Due Prothy $1.00
Atty Paid $37.25
Plaintiff Paid
Date: JULY 20, 2006
Other Costs
URTI LONG
Prothonotary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name ANDREW C. SPEARS, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
4660 TRINDLE ROAD, 3RD FLOOR
CAMP HILL, PA 17011