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HomeMy WebLinkAbout06-5260IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. ASSIGNEE OF CHASE MANHATTAN BANK h vv' 6 210 SYLVAN AVENUE ENGLEWOOD CLIFFS NJ 07632- Plaintiff VS ROBERT W SHAMU 524 HIGHLAND CT CARLISLE PA 17013 Defendant(s) CIVIL ACTION - LAW Filed on behalf of. Plaintiff, PALISADES COLLECTION L.L.C. / r Counsel of record for this party: Date: I I ?? 56L Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andre David R. Galloway #8732 onilyn M. Cluppie #8785 Sarah E. Ehasz #86469 / Roberto asTr. iiaZiT1 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 159501348 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) :CIVIL ACTION - LAW You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by an attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W&A File No. 159501348 IN THE COURT OF COMMON PLEAS OF CUM13ERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) :CIVIL ACTION - LAW USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias despuds que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamado en In Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante Para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013- 717-249-3166 CCP Notice to Defend W &A File No. 159501348 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK NO ?e l:fUtC,?E¢. Plaintiff VS ROBERT W SHAMU Defendant(s) :CIVIL ACTION - LAW AND NOW, comes the Plaintiff, by and through its attorneys and the law firm of Wolpoff & Abramson, LLP, and files this Complaint and in support avers as follows: Plaintiff is PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK , located at 210 Sylvan Avenue Englewood Cliffs, NJ 07632. 2. Defendant, ROBERT W SHAMU, is an adult individual with a last known address of 524 Highland Ct Carlisle, Cumberland County, PA 17013. It is averred that Defendant was issued an open end credit account (hereinafter "Account"). 4. At all relevant times material hereto, Defendant has been regular users of said Account for the purchase of products, goods and/or for obtaining services. 5. Defendant was provided with copies of the Statement of Accounts showing all debits and credits for transactions on the aforementioned credit card account to which there was no bona fide objection by Defendant. A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". 6. Defendant did not object to the above-mentioned statement submitted by Plaintiff and/or its assignors to Defendant. CCP Cmptt - WOR W &A File No. 159501348 As of the date of this Complaint, the remaining balance due, owing and unpaid on Defendant's credit card account as a result of the charges made by said Defendant and/or any authorized users is the sum of $9,411.47. 8. Interest has accrued from the charge off date at a rate of 18 %. 9. As of the date of the filing of this Complaint, the amount of interest which has accrued is the sum of $1,963.25. 10. As of the filing of this Complaint, Plaintiff has incurred reasonable attorney's fees from the law office of Wolpoff & Abramson, LLP in the collection of the amounts due from Defendant incident to the within action based upon 20% of the principal amount due and owing, and Plaintiff shall continue to incur such attorney's fees through the conclusion of the proceedings. 11. The amount of attorney's fees which has accrued is the sum of $1,882.29. 12. Despite reasonable and repeated demands for payment, Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 13. Plaintiff performed any and all conditions precedent to the bringing of this action. 14. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - WOR W &A File No. 159501348 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant in the amount of $9,411.47, plus interest in the amount of $1,963.25, plus attdmey's fees in the amount of $1,882.29, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully Submitted, Date: Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR W&A File No. 159501348 The undersigned hereby states that they are the attorney for the Plaintiff who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, they are authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Pleading are true and correct to the best of their knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unworn falsification to authorities. Date: Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. balloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, 3rd Floor Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff CCP Cmplt - WOR W &A File No. 159501348 Exhibit 11 A" PLAINTIFF = 425230 ACCOUNT NUMBER = 5491048251204487 POOL ID = CHASMP CURRENT BALANCE = 9411.47 LSTPYMTDT = 20050318 CO DATE = 20050531 DEBTOR #1 LAST NAME = SHAMU DEBTOR #1 FIRST NAME= ROBERT W DEBTOR #1 MIDDLE NAM= DEBTOR #1 ADDR 1 = 524 HIGHLAND CT DEBTOR #1 ADDR 2 = DEBTOR #1 CITY = CARLISLE DEBTOR #1 STATE = PA DEBTOR #1 ZIP = 170133923 DEBTOR #1 HOMEPHONE = 7172180814 DEBTOR #1 WORKPHONE - 00000000 DEBTOR #1 SOCSEC DEBTOR #1 DOB= DEBTOR #2 LAST NAME _ DEBTOR #2 FIRST NAME DEBTOR #2 MIDDLE NAM = DEBTOR #2 ADDR 1 = DEBTOR #2 ADDR 2 = DEBTOR #2 CITY = DEBTOR #2 STATE _ DEBTOR #2 ZIP = DEBTOR #2 HOMEPHONE _ DEBTOR #2 WORKPHONE DEBTOR # SOCSEC = DEBTOR#2 DOB = DEBTOR = 4148721 iA. tot w. N 3 u7 I i n 7 rT-_,' y ?. E. rY t.Jt V^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 06-5260- CIVIL TERM ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS CIVIL ACTION - LAW ROBERT W SHAMU Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), ROBERT W SHAMU , for failure to answer the Complaint. (X) Amount due Less credits TOTAL $13,257.01 $13,257.01, 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. ( X ) Pursuant to Pa.R.C.P. 237. 1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this praecipc_and a copy of the notice is attached. Date: 0 d?> )tW ??7 Amy F. Doy #87062 / Daniel F. Wolfson #20617 Phili ho Andrew C. Spears #87737 y avi all ay #877 onilyn M. Chippie #87852 Sad h E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, ZA0 .2 , 20L&, JUDG IS NTERE S ABOVE. Proth otary/Clerk visa By: Deputy W&A File No. 159501348 MAIN OFFICE TWO'IRVINGTOW CENTRE 702 KING FARM BLVD., ROCKVILLE, MO 20850 REGIONAL OFFICES 10805 JUDICIAL DR., BLDG. A-5, FAIRFAX, VA 22030 1108 E. MAIN ST., STE. 1003, RICHMOND, VA 23216 5122 GREENWICH RD., VIRGINIA BEACH, VA 23462 919 N. MARKET ST., STE. 1300, WILMINGTON, DE 19899 1 VAAEY BAN( BLDG, SM 1= QPgQBUHG, WV 28302 4660 TRINDLE ROAD, 3R0 FLOOR, CAMP HILL, PA 17011 28632 ROADSIDE DR., STE. 265, AGOURA HILLS, CA 91301 39500 HIGH POINTE BLVD., STE. 250, NOVI, MI 48375 300 CANAL VIEW BLVD., ROCHESTER, NY 14623 5215 N. OCONNOR BLVD., STE. 1080, LAS COLINAS, TX 75039 180 GLASTONBURY BLVD., GLASTONBURY, Cr oeo33 210 INTERSTATE NORTH PKWY., STE. 700, ATLANTA, GA 30339 301 CARLSON PKWY., STE. 303, MINNETONKA. MN 55435 LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection (A National Collection Attorney Network Firm) 4660 TRINDLE ROAD SUITE 300 CAMP HILL, PA 17011 717-303-6700 OUTSIDE THE CAMP HILL LOCAL AREA (TOLL FREE) 1-800-758-0675 FACSIMILE 717-737-9051 PLEASE DIRECT ALL INQUIRIES TO THE CAMP HILL OFFICE ROBERT W SHAMU 524 HIGHLAND CT CARLISLE, PA 17013 October 13, 2006 NATI N 1 TI N ATT NYE NETWORK A 1 LT F L OF TION N RE I N L WOLPOFF & A RAM N. L.LP.1 ` h- BIRMINGHAM, E6Ai?Kt36 NEW JERSEY ANCHORAGE, ALASKA RALEIGH, NORTH CAROLINA PHOENIX, ARIZONA FARGO, NORTH DAKOTA CABOT,ARKANSAS CLEVELAND, OHIO ENGLEWOOD, COLORADO OKLAHOMA CITY, OKLAHOMA FT. LAUDERDALE, FLORIDA EUGENE, OREGON HONOLULU, HAWAII PROVIDENCE, RHODE ISLAND BOISE, IDAHO COLUMBIA, SOUTH CAROLINA CHICAGO, ILLINOIS KNOXVILLE, TENNESSEE MERRILLVILLE, INDIANA SANDY, UTAH KANSAS CITY, KANSAS MILWAUKEE, WISCONSIN LEXINGTON, KENTUCKY RAWLINS, WYOMING METAIRIE, LOUSIANA ST. LOUIS, MISSOURI • The National Collection GREAT FALLS, MONTANA Attorney Network is an OMAHA, NEBRASKA affiliation of separate law firms. LAS VEGAS, NEVADA MANCHESTER, NEW HAMPSHIRE W&A Hours of Operation: 8 a.m.-5:30 p.m. ET M-F W&A File No. 159501348 1 RE: PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK vs. ROBERT W SHAMU Dear Robert W Shamu: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. Sincerely, G071 Enclosure cc: Amy F. Doyle #87U62 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.F. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff This is an attempt by a debt collector to collect a debt and any information obtained will be used for that purpose IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff vs. ROBERT W SHAMU Defendant(s) TO: ROBERT W SHAMU 524 HIGHLAND CT CARLISLE PA 17013 DATE OF NOTICE: October 13, 2006 NO. 06-5260- civil term CIVIL ACTION - LAW IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 717-249-3166 Amy F. Doyle #87b62 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 159501348 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) No. 06-5260- CIVIL TERM 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, Robert W Shamu, above-named, is over 21 years of age; is last known to reside at 524 Highland Ct Carlisle, 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 RQlief Act and its Amendments. "-ff ?/ Date: l0_2S of Amy F. Do a #87062 / Daniel F. Wolfson #20617 Phili 341 / Andrew C. Spears #87737 Davi R. Ga loway #873 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 dl5MM0NWll!A tW t3t? 14iiNNSYLVANIA Notarial Seat Kimberly L. Eisenhauer, Notary Public Hampden Twp., Cumberland County My Commission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this _Ny of OC Jbe( , 2006. Notary Public W & A File No. 159501348 W&A File No. 159501348 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) No. 06-5260- CIVIL TERM CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Palisades Collection,L.L.C. 210 Sylvan Avenue Englewood Cliffs NJ 07632 and certify that the last known address of the within Defendant(s) is: Robert W Shamu 524 Highland Ct Carlisle PA 17013 Date: z Amy F. Doyle 7062 / Daniel F. Wolfson #20617 faifyiid-CR-4Gal ' 41 / Andrew C. Spears #87737 way #8732 Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 159501348 N l n? (( pug ? ?_' "?) ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) No. 06-5260- civil term CIVIL ACTION - LAW NOTICE OF JUDGMENT ( x ) Notice is hereby given that a Judgment in the above-captioned matter has been entered against you in the amount of $13,257.01, plus interest, on 'Ain" Ca , 20Q6. ( x ) A copy of all documents filed with the Prothonotary in suppo f the within judgment is/am attached. By: '17 - If you have any questions regarding thi&'Notice, please c act the fili g party. Date: ,© w O Lo Amy F-3Doylt #87062 / Daniel F. Wolfson #20617 Phili W 6341 / Andrew C. Spears #87737 avid GalI ay #8732 onilyn M. Chippie #87852 Sarah E. Ehasz o ert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Robert W Shamu 524 Highland Ct Carlisle PA 17013 W&A File No. 159501348 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05260 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS SHAMU ROBERT W ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE SHAMU ROBERT W the DEFENDANT , at 0019:55 HOURS, on the 15th day of September, 2006 at 524 HIGHLAND COURT CARLISLE, PA 17013 by handing to ROBERT SHAMU a true and attested copy of NOTICE COMPLAINT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 / Service 4.40 roooo? Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.40,./ 09/18/2006 X0/0,( 0? WOLPOFF & ABRAMSON Sworn and Subscibed to B before me this day Deputy Sheriff' was served upon of , A. D. -.... PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION,L.L.C. IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF CHASE MANHATTAN BANK CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. ROBERT W SHAMU To the Prothonotary: JUDGMENT NO. 06-5260-CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Please issue the Writ of Execution in the above-captioned matter, in the amount of $13,257.01. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,ROBERT W SHAMU , 524 HIGHLAND CT, CARLISLE, PA 17013 , Defendant (s); (3) and against, COMMERCE BANK, 20 Noble Blvd # 1 , Carlisle, PA , Garnishee (s); (4) and index this writ (a) against, ROBERT W SHAMU > 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) 524 HIGHLAND CT 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 COMMERCE BANK, 20 Noble Blvd # I, CARLISLE, PA ,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 $13,257.01 Interest from 11/2/2006 To Be Determined At an interest rate of 6% per year Total $13,257.01 Plus costs & interest _Z?? Date: 312-2 (9'1 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 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 159501348 XXX-XX-4117 (? w o:b ti a c, c 4Q. ?? Ala 9-11 W Sup ?. o o © a {aa ?u :rD r cis ? .?-- ,;.z co } c o WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff (s) From ROBERT W SHAMU, 524 HIGHLAND CT, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL NO 06-5260 Civil CIVIL ACTION - LAW 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. #1, CARLISLE, PA ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITILE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. and to notify the gamishee(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 $13,257.01 L.L. $.50 Interest FROM 11/2/2006 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $123.90 Plaintiff Paid Date: 03-28-07 (Seal) Due Prothy $2.00 Other Costs C is R. Lon onot By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF ., Telephone: 717-303-6700 Supreme Court ID No. 87062 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) No. 06-5260-CIVIL TERM CIVIL ACTION - LAW '7" 4 INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION 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. 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 issued. TO: COMMERCE BANK 20 NOBLE BLVD # 1 CARLISLE, PA B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ of Execution was 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. W&A File No. 159501348 XXX-XX-4117 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - ROBERT W SHAMU 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. Db I A. 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. Db 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. Ab 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. Db 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) which are not disclosed in the preceding Interrogatories. If so, please set forth all details concerning those asset. Db W&A File No. 159501348 XXX-XX-4117 I A4 I 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 each item of property including its value. lib 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 each item of property including its value and the interest held by the Defendant(s). )`b 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). Db 8. TRANSFER OF PROPERTY: At any time before or after you were served, did 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. Ab 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. Ab Date: 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 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 ";ommetce Bank Counsel for Plaintiff 3801 Paxton Street Harrisburg, PA 17111 717-412-6134 Date u7 W&A File No. 159501348 XXX-XX-4117 o .., - m ; cs HIM irf'? ni ? . t ? ' y CO cn w "< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 06-5260-CIVIL TERM ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS ROBERT W SHAMU Defendant(s) CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, COMMERCE BANK, discontinued, upon payment of your costs only. Respectfully Submitted, Date: ©-f Amy F. Doyle 2 / 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 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 159501348 -?A,. -r? ? a ? ??_ . ?_ ?,?,?. ?. _ ?,? ? ? ? r A ?? 1 VV _\ ?? ? ? SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-05260 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS SHAMU ROBERT W And now CPL. RICHARD SMITH ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0008:40 Hours, on the 2nd day of April , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , SHAMU ROBERT W hands, possession, or control of the within named Garnishee 4660 TRINDLE ROAD SUITE 300 CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to AMANDA WILLIAMS (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 answers .00 .00 .00 R. Thomas Kline _ .00 b? Sheriff of Cumberland County .00 0 0 J5 ???'o 05/03/2 before me this day of By A.D 10 % I R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no 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 Sheriff's Costs 101.99 18.00 48.91 1.99 .50 2.00 Refunded to Atty on 04/30/08 9.60 40.00 20.00 9.00 / 101.99 ? SlOYl b Y 9, So?Ap?wmoor R. Thomas Kline, Sheriff ?.cM h 3 817 a 0 E ST3 0 LIN WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5260 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff (s) From ROBERT W SHAMU, 524 HIGHLAND CT, 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 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. #1, CARLISLE, PA ALL ACCOUNTS INCLUDING BUT NOT LIMITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITILE, 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 $13,257.01 L.L. $.50 Interest FROM 11/2/2006 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $123.90 Plaintiff Paid Date: 03-28-07 (Seal) Due Prothy $2.00 Other Costs Cu R. Lon thono By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011