The URL can be used to link to this page

Home My WebLink About06-5262IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS NJ 07632- Plaintiff No. VS LEISHA M WAGNER 4 COURTLAND DR CAMP HILL PA 17011 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, PALISADES COLLECTION,L.L.C. J ?Counsel of record for this party: Date: (3l? 07/ Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Philip C. Warholic #86341 / Andrew #tt7737 David R. Galloway #873 onilyn le Sarah E. Ehasz #86469 / Roe o as, r. IFLOM9 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. 159501301 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS LEISHA M WAGNER 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. 159501301 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS LEISHA M WAGNER 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 1'a 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. 159501301 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIG1 EE OF CHASE MANHATTAN BANK Plaintiff VS LEISHA M WAGNER Defendant(s) :No. OG S1 r, Z :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, LEISHA M WAGNER, is an adult individual with a last known address of 4 Courtland Dr Camp Hill, Cumberland County, PA 17011. 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. 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 Cmplt - WOR W&A File No. 159501301 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 $7,184.04. 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 $1,498.61. 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 $1,436.81. 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. 159501301 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant in the amount of $7,184.04, plus interest in the amount of $1,498.61, plus att Irney's fees in the amount of $1,436.81, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully Submitted, Date: J h 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 3 W &A File No. 159501301 VERIFICATION 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. 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 4 W&A File No. 159501301 Exhibit "A" PLAINTIFF = 425230 ACCOUNT NUMBER = 5222760050016641 POOL ID = CHASMP CURRENT BALANCE = 7184.04 LSTPYMTDT = 20050317 CO DATE = 20050531 DEBTOR #1 LAST NAME = WAGNER DEBTOR #1 FIRST NAME = LEISHA M DEBTOR #1 MIDDLE NAM = DEBTOR #1 ADDR 1 = 4 COURTLAND DRIVE DEBTOR #1 ADDR 2 = DEBTOR #1 CITY = CAMP HILL DEBTOR #1 STATE = PA DEBTOR #1 ZIP = 170110000 DEBTOR #1 HOMEPHONE = 7177377928 DEBTOR #1 WORKPHONE = 0000000000 DEBTOR #1 SOCSEC DEBTOR #1 DOB= DEBTOR #2 LAST NAME _ DEBTOR #2 FIRST NAME _ DEBTOR #2 MIDDLE NAM = DEBTOR #2 ADDR 1 = 4 Courtland Rd DEBTOR #2 ADDR 2 = DEBTOR #2 CITY = CAMP HILL DEBTOR #2 STATE = PA DEBTOR #2 ZIP = 17011 DEBTOR #2 HOMEPHONE = 7177377928 DEBTOR #2 WORKPHONE = 0000000000 DEBTOR # SOCSEC = DEBTOR#2 DOB = DEBTOR = 4140689 n? J 1 J r q7 (?f Li r:> ;7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 06-5262 CIVIL TERM ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS CIVIL ACTION - LAW LEISHA M WAGNER Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), LEISHA M WAGNER, for failure to answer the Complaint. (X) Amount due Less credits TOTAL $10,119.46 $10,119.46, 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 praecipe and a copy of the notice is attached. Date: f-7 )a, F.. Amy F. Doyle 062 / Daniel F. Wolfson - Philip C. Warholic #86341drew 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 NOW, S" , 20-0G , JUDGMEE RED AS OVE. Prothono IClerk, vision By: Deputy W&A File No. 159501301 MAIN OFFICE TWO IRVINGTON CENTRE 702 KING FARM BLVD., ROCKVILLE, MD 20650 REGIONAL OFFICES 10605 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 VALLEY BANK BLDG., BOX 1226, CLARGSBURG, WV 26302 4660 TRINDLE ROAD, 3RD FLOOR, CAMP HILL, PA 17011 28832 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. O'CONNOR BLVD., STE. 1080, LAS COLINAS, TX 75039 180 GLASTONBURY BLVD., GLASTONBURY, CT 08033 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) LEISHA M WAGNER 4 COURTLAND DR CAMP HILL, PA 17011 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 October 23, 2006 NAT LJ? L A N NM % D RRiIA AT k ?I?N3`?N? RR LWFIGC€ gF WStP'?FF & ABRAM$R1. L.L. .I' BIRMINGHAM, QEUAR KNOLLS' 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 attlllatton 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. 159501301 1 RE: PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK vs. LEISHA M WAGNER Dear Leisha M Wagner: Enclosed herein please find a 10-Day Notice pursuant to Rule 237.1 of the Pennsylvania Rules of Civil Procedure. COO p?( Enclosure cc: cerel , Amy F. Doyle #87062 / Daniel F. Wolfson #20617 Phil' 341 / Andrew C. Spears #87737 Da i R. Ga loway #8732 onilyn 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 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. NO. 06-5262 civil term ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff vs. CIVIL ACTION - LAW LEISHA M WAGNER Defendant(s) TO: LEISHA M WAGNER 4 COURTLAND DR CAMP HILL PA 17011 DATE OF NOTICE: October 23, 2006 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 #87062 / Daniel F. Wolfson #20617 Z:g:i"d olic /Andrew C. Spears #8777 wa #87Tonilyn M. Chippie #87852 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. 159501301 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 06-5262 CIVIL TERM ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS CIVIL ACTION - LAW LEISHA M WAGNER Defendant(s) 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: Leisha M Wagner 4 Courtland Dr Camp Hill PA 17011 Date: 1 )C4 Amy F. Doyle # 062 / Daniel F. Wolfson 17 Philip C. Warholic #8634, 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. 159501301 . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff No. 06-5262 CIVIL TERM VS LEISHA M WAGNER Defendant(s) CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, Leisha M Wagner, above-named, is over 21 years of age; is last known to reside at 4 Courtland Dr Camp Hill, 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. Date: Amy F. Doyle#87062 / Daniel F. Wolfson "617 _ Philip C. Warholic #86341 / C. Spears #87 David R. Galloway #87326 / oni yn ippie #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 SWORN and SUBSCRIBED to before me this. I day of 20 mi=l Notary Public W & A File No. 159501301 MQMff&M0F IM __ ____L4 Notarial eeei ?Y M. F tmk N tRNy Pubk Hampden lwp. Cwfte" County Member, Penneykwis AoeocWon of Notaries W&A File No. 159501301 I , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 06-5262 civil term ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS CIVIL ACTION - LAW LEISHA M WAGNER Defendant(s) 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 $10,119.46, plus interest, on ?yOU . !S , 20Q1. ( x ) A copy of all documents filed with the Prothon in sup f the within judgment is/are attached. By: If you have any questions regarding this Notice, p ease co ct the fili g party. 1-7 Ink , 1 Date: Amy F. Doy e 2 / Daniel F. Wolfsn JV_0617 Philip C. Warholic #86341 / dfew C. Spears #877 David R. Galloway #87326 / om yn 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 This Notice is given in accordance with Pa.R.C.P. 236.) NOTICE SENT TO: Leisha M Wagner 4 Courtland Dr Camp Hill PA 17011 W&A File No. 159501301 SHERIFF'S RETURN - REGULAR CASE NO: 2006-05262 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS WAGNER LEISHA KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon G7A("-'TTVD T.1:TCUn M the DEFENDANT , at 1833:00 HOURS, on the 20th day of September, 2006 at 4 COURTLAND ROAD CAMP HILL, PA 17011 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 11.44 Postage .39 Surcharge 10.00 R. Thomas Kline .00 39.83/ 09/21/2006 4- WOLPOFF & ABRAMSON io/bv/64 Sworn and Subscibed to By: before me this day of A.D. .11111'eritZSh V4 f f In the Court of Common Pleas of Cumberland County LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. PATRICIA E. NOLAN (Mortgagor(s) and Record Owner(s)) 4714 E. Trindle Road Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 05-5262 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PATRICIA E. NOLAN by default for want of an Answer. Assess damages as follows: Debt $59,280.95 Interest from 12/16/06 to Date of Sale Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIF AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN F THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to e p against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least s prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Gold , J . Attorney for Pla' iff I.D. #16132 AND NOW _0?00& , Judgment is entered in favor of LASALLE BANK NA A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000- 3, AS ISSUER, SUPERIOR BANK and against PATRICIA E. NOLAN by default for want of an Answer and damages assessed in the sum of $59,280.95 as per the above certification. Pro notary Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000- 3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. PATRICIA E. NOLAN (Mortgagors and Record Owner(s)) 4714 E. Trindle Road Mechanicsburg, PA 17055 Defendant(s) No. 05-5262 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothono By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 12/19/2006 16:12 FAX 215 627 7734 GOLDBECK • 002 EMC-0968 TII'IS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING Tp COLLECT A DE10T OWED TO OUR CLI NT. ANY INFORMATION OBTAINED FROM YOU WILL, BE USED FOR TIM PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NO'T'ICE: December 4, 2006 TO: PATRICIA E. NOLAN 4714 E. Trindle Road Mechanics, PA 17055 i LASALLE BANK NA F'/K/A L I h ASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UND n t e Court of Common Pleas ER THAT CERTAIN SALE SERVICING AGREEMENT DAM of Cumberland County OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER SUPERIOR BANK CI , 1270 Northland Drive, Ste. 200 VIL ACTION - LAW Mendota Heights, MN 55120 Action of Plaintiff Mortgage Foreclosure Vs. PATRICIA B. NOLAN Term (Mortgagor(s) and Record Owner(s)) No. 05-5262 4714 E. Txilndle Road Mechaxlicsburg, pA 17055 Defendant(s) TO: PATRICIA 1L. NOLAN 4714 E. Trindle Road Mmhanicsburg, PA 17055 IDIP 11RTANT NOTICIF YOU AR1; IN DEFAULT DECAUSE YOU HAVE FAILED TO ENTER A wRrTTEN APPEO CE PERSONALLy OR By ATTORNEY AND xILE'N WRIZTAIG WIUI nffi COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAW SET FORTH AGAINST YOU. UNLESS YOU ACT WIrIlIN TEN (10) DAYS FROM THE PATE OF TWS NOTICE, A JMGMENT MAY BE ENTERED AGAINST YOU WrMOUT A OTHER 11?'ORTANT RIGHTS. YOU SHOULD 'T'AKE HEARING AND YOU MAY LOSE YOUR PROPERTY OR HAVE A THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT WYM GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW THIS OFFICE CAN PROVIDE YOUWITH INFORMATION ABOUT HIRING A LAWYER- XF YOU CANNOT AFFORD TO HIRE A LAWYER, ABLE TO PROVDD13 YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER THIS LEGAL SERVI SER MAY B$ ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. FFirR CkS TO LEDGA1. SERV1cEs iNC 8lrviee Row Cw isk PA 17013 717.243-9400 CUMBERLAND boUNry BAk ASSOCIATION 2 Ubety Avenue Cadislq PA 17013 ,?a?rfCz? ?,??r GOLDBECK McCAFFERTY & McKEEVI;R By'-' Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street Pidladelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PATRICIA E. NOLAN, is about unknown years of age, that Defendant's last known residence is 4714 E. Trindle Road, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That. Defendant is not in the Military or Naval Service of the United States or its Allies, or o7iilR?lief ise within the provisions of the Soldiers' and Sailors' Ci Action of Congress of 1940 and its Amendments. Date: GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. PATRICIA E. NOLAN (Mortgagor(s) and Record owner(s)) 4714 E. Trindle Road Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 05-5262 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK, and against PATRICIA E. NOLAN for failure to file an Answer in the above actio n (20) days (or sixty (60) days if defendant is the United States of America) from the date of service o the Co plaint, in the sum of $59,280.95. Joseph A. G, Attorney for I hereby certify that the above names are correct and that the precise si e address of the judgment creditor is LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DA CTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1 70 No Wand Drive, Ste. 200 Mendota Heights, MN 55120 and that the name(s) and last known address(es of the efendant(s) is/are PATRICIA E. NOLAN, 4714 E. Trindle Road Mechanicsburg, PA 17055; GOLDBECK McC E & MCKEEVER BY: Joseph A. Gol k, Jr. Attorney for Plaintiff s ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $51,371.67 Interest from 04/01/2005 through $3,006.98 12/15/2006 Reasonable Attorney's Fee $2,568.58 Late Charges $181.32 Costs of Suit and Title Search $900.00 $59,280.95 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney for Plaintiff AND NOW, this ! 44kday Of 2006 damages are assessed as above. 4rothy 47-- rn f i? r io - Co ,111 ?j PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff i.HJAL,EE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff VS. PATRICIA E. NOLAN Mortgagor(s) and Record Owner(s) 4714 E. Trindle Road Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS ACTION OF MORTGAGE FORECLOSURE of Cumberland County CIVIL ACTION - LAW No. 05-5262 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 12/16/06 to Date of Sale at 8.2500% $59,280.95 (Costs to be added) GOLDBECK MCCAI BY: Joseph A. Goldb Attorney for Plaintiff Jr. McKEEVER W a O N `O O H°O za O U x H 4 U W H u 0? z ?w W w UQ QUW Ori z?HwN pq P A Wy W rte- W ?" t'? vi 7zWvFi a? ?H O zz W" x;77 ¢O o0 W W O O W P4 ? °° F U an o a P/?la + v 4r y v v V v of 14. ZrI ?r V ti .U' Q b 0 ti a4 ?U 79 Z U ? b?N wax ?? ?Cr?iO ?N .a L7 ? J . All that certain tract or parcel of land situate in Hampden Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described according to a survey of D.P. Raffensperger, Registered Surveyor, dated August 30, 1957, as follows: Beginning at a point on the southern line of Trindle Road, 783 feet west of the intersection of the southern line of Trindle Road with the center line of Route #A-1614, also being at the western line of lands now or formerly of Thomas C. Mitchell; thence south 25 degrees 23 minutes east along same, 150 feet to a point; thence south 68 degrees 52 minutes west, 80 feet to a point in the eastern line of a proposed 40 foot wide street; thence north 25 degrees 23 minutes west along same, 150 feet to a point on the southern line of Trindle Road, also being the southeast, corner of the intersection of Trindle Road and the hereinbefore mentioned proposed 40 foot wide street; thence eastwardly along the southern line of Trindle Road, 80 feet to a point, the place of beginning. BEING KNOWN AS 414 E. TRINDLE ROAD, MECHANICSBURG PA 17055 TAX PARCEL NO: 10-22-0527-146 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) AS ISSUER SUPERIOR BANK, Plaintiff (s) NO 05-5262 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNT AFC TRUST SERIES 2066-1 From PATRICIA E. NOLAN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $59,280.95 L.L. $.50 Interest FROM 12/16/06 TO DATE OF SALE AT 8.2500% Atty's Comm % Due Prothy $1.00 Atty Paid $122.48 Plaintiff Paid Date: DECEMBER 19, 2006 (Seal) Other Costs C s R. Long, notary By: REQUESTING PARTY: Deputy Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 C Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 Plaintiff vs. PATRICIA E. NOLAN (Mortgagor(s) and Record Owner(s)) 4714 E. Trindle Road Mechanicsburg, PA 17055 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 05-5262 LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 4714 E. Trindle Road Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): PATRICIA E. NOLAN 4714 E. Trindle Road Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PATRICIA E. NOLAN 4714 E. Trindle Road Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND CO. ADULT PROBATION 1 Courthouse Square Carlisle, Pa 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 4714 E. Trindle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and convect to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to pen ties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 14.2006 GOLDBECK MCCAI BY: Joseph A. Goldb Attorney for Plaintiff ? ?a ca - - ? i c-.-7 ?-? `77 _Y_ ? t T ( 4.1.. ,? T -, CAP) '' -? ` `.---? ._._. i ?. J ?` b 05-5262 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTA SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK 1270 Northland Drive, Ste. 200 Mendota Heights, MN 55120 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs. PATRICIA E. NOLAN Mortgagor(s) and Record Owner(s) 4714 E. Trindle Road Mechanicsburg, PA 17055 Defendant(s; Term No. 05-5262 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NOLAN, PATRICIA E. PATRICIA E. NOLAN 4714 E. Trindle Road Mechanicsburg, PA 17055 Your house at 4714 E. Trindle Road, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 13, 2007, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $59,280.95 obtained by LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 05-5262 1. The sale will be cancelled if you pay to LASALLE BANK NA F/K/A LASALLE NATIONAL BANK, IN ITS CAPACITY AS INDENTURE TRUSTEE UNDER THAT CERTAIN SALE SERVICING AGREEMENT DATED OCTOBER 1, 2000 AMOUNG AFC TRUST SERIES 2000-3, AS ISSUER, SUPERIOR BANK, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866413-2311 and 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 05-5262 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionagoldbecklaw.com. Call Judy at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of EMC-0968. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. - C=7 -i ?v, ec PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 06-5262 CIVIL TERM LEISHA M WAGNER Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $10,119.46. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,LEISHA M WAGNER located at 4 COURTLAND DR, CAMP HILL, PA 17011, Defendant (s); (3) and against, MEMBERS I ST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588, Garnishee (s); (4) and index this writ (a) against, LEISHA M WAGNER , Defendant (s) and (b) against, MEMBERS 1 ST 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) 4 COURTLAND DR CAMP HILL, PA 17011 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 1 ST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013-1588, 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 $10,119.46 Interest from 11/15/2006 To Be Determined At an interest rate of 6% per year Total $10,119.46 Plus costs & interest Date: f ` 414 h ) 11A. A Amy F. Doyle #87062 Daniel F. olfson #20617 Philip C. Warholic #86A41 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis 418837 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. 159501301 XXX-XX-3358 R Q? m V ( IA 49. J `4. ?^ ?Q t C) c 0 70 o -n - -, TI a rr, Q Z? WRIT OF EXECUTION and/or ATTACHMENT r- '-.. 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 LEISHA M. WAGNER, 4 COURTLAND DR., CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL NO 06-5262 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(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 1sT FCU LOCATED AT 1000 BRYN MAWR RD., CARLISLE, PA 17013-1588 - 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. 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 $10,119.46 L.L. $.50 Interest FROM 11/15/06 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $131.33 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JUNE 29, 2007 (Seal) Deputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, 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. 86341 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff No. 06-5262 CIVIL TERM VS CIVIL ACTION - LAW LEISHA M WAGNER Defendant(s) k) INTERROGATORIES TO GARNISHEE IN AID OF EXECUTION TO: MEMBERS 1 ST FCU 1000 BRYN MAWR RD CARLISLE, PA 17013-1588 PURSUANT TO RULE 3253 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. issued. 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. 159501301 XXX-XX-3358 PLAINTIFF'S INTERROGATORIES TO GARNISHEE DEFENDANT(S) - LEISHA M WAGNER 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. Sow* c4le (- CV -e-c" 9 5kv s IIc C ?l? X31 - ?P?S _,bt ti-a'? SCC?`g? ^ 22-. 1 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. *-s- 1a31LA,1 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. Nu 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. ICJ 4. TRANSFER OF PROPERTY: At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 5. 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. 1vv W&A File No. 159501301 XXX-XX-3358 6. REAL OR 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. P"O 7. 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. 00 8. 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). 00 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" - , fxzz / jl?LA Z.46Z Date: (; o 16 Amy F. Doyle 48706 / Daniel . Wolfson 42061 Philip C. Warholic 06141 / 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. 159501301 XXX-XX-3358 n ?? p -n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Palisades Collection LLC Plaintiff vs. LEISHA WAGNER Defendant NO. 06-5262 CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, MEMBERS FIRST FCU, discontinued, upon payment of your costs only. Respectfully Sub}nitted, Dated: W&A File No. 159501301 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 cc: James Bach, Esq 352 S. SPORTINGHILL RD. MECHANICSBURG, PA 17050 +.J t< 00 7c # 48 7 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED, due to BANKRUPTCY. Sheriff's Costs: Advance Costs: 150.00 131.28 Docketing 18.00 $ 18.72 Poundage 2.58 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 07/31/07 Mileage 19.20 Surcharge 40.00 Levy 40.00 Certified Mail Post Pone Sale Garnishee 9.00 Postage TOTAL $ 131.28 ? 'yla `' ?? 7 o Answers- R. Thomas Kline, heriff ej Cl t.J 1 ?t QJ By Claudia A. Brewbaker ' SU ciz S 9 3.2J f?? y s p:2 v 0 N WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-5262 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 LEISHA M. WAGNER, 4 COURTLAND DR., CAMP HILL, PA 17011 (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 1sT FCU LOCATED AT 1000 BRYN MAWR RD., CARLISLE, PA 17013-1588 - 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. 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 $10,119.46 L.L. $.50 Interest FROM 11/15/06 AT AN INTEREST RATE OF 6% PER YEAR Atty's Comm % Atty Paid $131.33 Plaintiff Paid Date: JUNE 29, 2007 (Seal) Due Prothy $2.00 Other Costs lieputy REQUESTING PARTY: Name PHILIP C. WARHOLIC, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011