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Home My WebLink About06-5307IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. Q(o -. ,S' T Ctui LC ASSIGNEE OF CHASE MANHATTAN BANK 210 SYLVAN AVENUE ENGLEWOOD CLIFFS NJ 07632- Plaintiff VS KRISTIN E STOCKSLAGER 210 S 17 ST CAMP HILL PA 17011 JASON STOCKSLAGER 210 S 17TH ST CAMP HILL PA 17011-0000 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, PALISADES COLLECTION,L.L.C. Counsel of record for this party: Date: )S2 )(W Amy F. Doyle #87062 / Daniel Philip C. Warholic #8634 Andrew C. Spears #87737 David R. Galloway #873261 om 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 W&A File No. 159495198 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS :CIVIL ACTION - LAW KRISTIN E STOCKSLAGER JASON STOCKSLAGER Defendant(s) 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 WIRE 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. 159495198 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS :CIVIL ACTION - LAW KRISTIN E STOCKSLAGER JASON STOCKSLAGER Defendant(s) 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 despues 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 qs 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 1k 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. 159495198 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. OI. -- SOO 7 ASSIG E OF CHASE MANHATTAN BANK Plaintiff VS KRISTIN E STOCKSLAGER JASON STOCKSLAGER 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: 1. Plaintiff is PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK , located at 210 Sylvan Avenue Englewood Cliffs, NJ 07632-. 2. Defendant, KRISTIN E STOCKSLAGER, is an adult individual with a last known address of 210 S 17 St Camp Hill, Cumberland County, PA 17011. 3. Defendant, JASON STOCKSLAGER, is an adult individual with a last known address of 210 S 17Th St Camp Hill, Cumberland County, PA 17011-0000. 4. It is averred that Defendants were issued an open ended credit account (hereinafter "Account"). 5. At all relevant times material hereto, Defendants have been regular users of said Account for the purchase of products, goods and/or for obtaining services. 6. Defendants were 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 CCP Cmplt - WOR 2 W&A File No. 1 59495 1 98 objection by Defendants. A true and correct copy of the Statement of Account is attached hereto, incorporated herein and marked as Exhibit "A". 7. Defendants did not object to the above-mentioned statements submitted by Plaintiff and/or its assignors to Defendants. 8. As of the date of this Complaint,, the remaining balance due, owing and unpaid on Defendants' credit card account as a result of th? charges made by said Defendants and/or any authorized users is the sum of $13,183.14. 9. Pursuant to the applicable Pennsylvania law, any unpaid or delinquent balances on said account shall continue to bear interest at the rate of 18 %. 10. The amount of interest which has accrued from the charge off date is the sum of I $6,306.23. 11. 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 Defendants 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. 12. The amount of attorney's fees which has accrued is the sum of $2,636.63. 13. Despite reasonable and repeated demands for payment, Defendants have refused and continue to refuse to pay all sums due and owing on the aforementioned account balance, all to the damage and detriment of the Plaintiff. 14. Plaintiff performed any and all conditions precedent to the bringing of this action. 15. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. CCP Cmplt - WOR 2 2 W&A File No. 159495198 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plai tiff and against Defendants in the amount of $13,183.14, reasonable attorney's fees in the amount of $2,636.63, plus interest in the amount of $6,306.23, 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 Cmpit - WOR 2 W&A File No. 1 59495 1 98 VERIFICATION The undersigned hereby states that they are the attorney for the Plaintiff who is located outside of this j?risdiction 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 i 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 2 4 W&A File No. 1 5 9495 1 98 Exhibit "A" Pf AINTIFF = 425230 ACCOUNT NUMBER = 5466757002501394 POOL ID = CHASAR CURRENT BALANCE = 13183.14 LSTPYMTDT = CO DATE = 20031130 DEBTOR #1 LAST NAME = STOCKSLAGER DEBTOR #1 FIRST NAME = KRISTIN E DEBTOR #1 MIDDLE NAM= DEBTOR #1 ADDR 1 = 210 S 17 ST DEBTOR #1 ADDR 2 = DEBTOR #1 CITY = CAMP HILL DEBTOR #1 STATE = PA DEBTOR #1 ZIP = 17011 DEBTOR #1 HOMEPHONE = 7179759299 DEBTOR #1 WORKPHONE = 0000000000 DEBTOR #1 SOCSEC DEBTOR #1 DOB = DEBTOR #2 LAST NAME = STOCKSLAGER DEBTOR #2 FIRST NAME = JASON DEBTOR #2 MIDDLE NAM = DEBTOR #2 ADDR 1 = 210 S 17TH ST DEBTOR #2 ADDR 2 = DEBTOR #2 CITY = CAMP HILL DEBTOR #2 STATE = PA DEBTOR #2 ZIP = 170115509 DEBTOR #2 HOMEPHONE = 7179759299 DEBTOR #2 WORKPHONE = 0000000000 DEBTOR # SOCSEC = DEBTOR#2 DOB = DEBTOR = 4218287 v1 V :Y1 loo IN THE COURT OF COMMON PLEAS OF CMMnLAND COUNTY, PRMSYLVARIA PALISADES COLLECTION, L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff, NO. 06-5307 vs. KRISTIN E STOCKSLAGER CIVIL ACTION - LAW JASON STOCKSLAGER Defendants. USPONSE T"QMPLAINI Defendants, Kristin E. Stockslager and Jason Stockslager ("Defendants") answering for themselves and no other defendants, responds to the plaintiff Palisades Collections, L.L.C. Assignee of Chase Manhattan Bank ("Plaintiff's') Complaint as follows; 1. Defendants have no knowledge to either admit or deny the allegations in Paragraph I of the Complaint and therefore deny all of the allegations contained therein. 2. Defendant admits the allegations contained in Paragraph 2 of this Complaint. 3. Defendant admits the allegations contained in Paragraph 3 of this Complaint. 4. Defendants cannot admit to all of the allegations contained in Paragraph 4 of this Complaint and therefore deny all of the allegations contained therein. 5. Defendants cannot admit to the correctness of all of the information in Paragraph 5 of this Complaint and therefore deny all of the allegations contained therein. 6. Defendants deny the allegations contained in Paragraph 6 of the Complaint because we have repeatedly requested a validation of this debt and Plaintiff has failed to provide a validation of this debt instead a hearsay recitation of the account. 7. Defendants deny the allegations contained in Paragraph 7 of this Complaint as we requested Validation of the alleged contract and were never given the information that we requested. In lieu of the requested information we were sent a prolix printed form drafted by the party who is attempting to enforce the disputed terms. Prior to this time we had never seen this alleged agreement and had we seen it we probably would have refused this credit card. 8. Defendants deny the allegation contained in Paragraph 8 of this Complaint, 9. Defendants deny the allegations contained in Paragraph 9 of this Complaint because there is no agreement and Plaintiff has failed to provide a signed copy of the alleged agreement. 10. Defendants deny the allegations contained in Paragraph 10 of this Complaint because any interest charge would be a matter of contract and there is no valid and enforceable contract. 11. Deferutants deny the allegations contained in Paragraph l 1 of this Complaint because there are no reasonable attorney fees associated with the enforcement of an invalid contract. 12. Defendants deny the allegations contained in Parsg wh 12 of this Complaint. See the response to Paragraph 11. msm - t 13. Defendants deny the allegations contained in Paragraph 13 of this Complaint because we have repeatedly requested a validation of the contract and alleged debt to no avail. 14. Defendants decry the allegations contained in paragraph 14 of this Complaint because Plaintiff had never validated the debt. 15. Defendants deny the allegations eoolmioed in Pwagtqh 17 of Via Complarnt. FtRff 11 =Ip$ DEFENSE 16 The Complaint, and each purported cause of action alleged in it, fails to state facts sufficient to constitute a cause of action against these answering Defendants. BBC= "FXMMTM DEFENSE 17 Defendants allege that, without conceding that the Plaintiffhas sustained any damages alleged in its Complaint, if Plaintiff sustained such damages, it is a result of Plaintiffs failure to mitigate its damages, Plaintiff failed to provide substantial "Validation" of the written/ax&actuai terms pursuant to the Fair Debt Collection Practices Act (hercinaiter FDCPA) §809,15 USC 1692 and as disputed by Defenda=nt. TIMM AFFItI'ln IM n sB 18. Defendants are informed and believe, and on that basis alleges that Plaintiffhas waived any right to any relief as alleged in the Complaint and is estoppel by its own conduct or by conduct within its control from asserting that it is entitled to any relief asserted in the Complaint. POO= AFFIMTM OxF=z 19, Defrttdastts allege that Plaintiff is barred tmm any relief or recovery by the doctrine of Laches. F117Tn APPI ATM DEFENSE 20. Defendants allte than fine iff is bared from any rdad or recarmy by the doctrine of Unclean Hands. SIM aFF'IMTWZ DEFSNSS 21. Defendants allege that Plaintiff failed to comply with one or more conditions precedent by failing to provide Defmdani with a copy of any agreement between the parties as required by FDCPA §809,15 USC §1692, Defendants are entitled to, and have requested "'Validation" of such contract or agreement signed by the Defendants. However Plaintiff has failed to provide Defendants with any signed contract or agreement in response to Defendant's request for "'Validation." Plaintiff's neglect to comply or satisfy the statutes under the aforementioned authority of the FDCPA can be construed as an absolute waiver or any and all claims against me. Therefore, Plaintiff does not have any substantial provable terms to enforce any contractual agreement allegedly entered into with the Defendants. SIVSNTN "F3:nMTM DEMSE 22. Defendants allege that, without conceding that Plaintiff has sustained any damages as alleged in their Complaint, if any such damages were sustained by Plaintiff, they were caused and coatn'buted to by the actions of the Plaintiff and/or their agents or representatives, and that the award or damages, if any, should be reduced by the proportionate percentage of the wrong attributable to the Plaintiff, its agents or representatives. 71DiSM - 2 BIGWH 11I TAMTIVB DEFENSE 23. Defendants allege that, without conceding that Plaintiff has sustained any damages as alleged in their Complaint, if Plaintiff sustained any such damages, they were caused by persons or entities other than these answering Defendants, and at all tunes, these other persons or entities were acting without the consent, authorization, knowledge or ratification of these answering defendants with regard to any and all of the acts alleged in the Complaint, and the award of damages, if any, should be reduced by the proportionate percentage of wrong attributable to those persons or entities. iti0 4 Yc e li-r?11?w>>l+w .3ttOr[ a+ +il??:A aci?+ !it_.c c.ifv l:4i c?iG 24. iefrxuiruiw illegality of a contract defense. 25, c fcnd au64-UCgf, ?yjQ4 j[Ia-,- .ti Jc Ar.,?+tu?, ww[wt? ?tl?? Ilf Al_:il::! cccG: lb: 1. :J \[iYlVY by the applicable statutes of limitations. Ti.i SilG•[-y-i'ii 9Y'_ .1 v nJ iF.F 4l?.J Fi X Defendants allege that the Plaintiff has failed to allege facts sufficient to constitute a basis for an award of attorney's fees against these answering Defendants. TWELFTH AFFIMATIVE DEFENSE 27, Defendants may have additional affirmative defenses available to them, which they are not now fully aware of Defendants reserve the right to assert said affirmative defenses after the same has been ascertained. f !! ANSMM - 3 PRAYER Defendants pray for judgment against plaintiff as follows: 1. That Plaintiff take nothing by way of its Complaint on file herek and that the same be dismissed with prcju&e; 2. That Dehndants Mover the costs of this suit and amble attorneys fees incwred herein; and 3. For such O&W nd finthcr reef lbat that Corot deem jvd and proper DATED: i o i b OCo IMISTYN R sTOCltsLi?G DZFWWANT, XX PRO P JASON STOCKSLKGM D BNDANT, IN PRO PER ANSKR - 4 EXHIBIT °1" 210 S.1TTH ST. CAW HILL PA 17011 Oc kim 10, 2006 Via USPS Deit"CIM1111 A&M W- 03041500000117OMTO Wolpoff & Abramson I.L.P. 4560 Trindle Rd 3rd Floor (fir" Hk PA 17011 Re: Pam Collection LLC v. JASON STOCKSI ANGER and KMSTM STOCKSLALER Case No. 06.rW Aam urt No. 546&?SM4MI394 (leer Wdpolf & Abramson LL.P.: I am in recut of the Summons and Complaint in the abwis-ernitled matter. After 1 reviewed the Complaint and aftedw documents, I realized that I have never received cry carr+espondenoe from your office pursuant to I?CPA $809(b). It is to my iutowbdge that, accord'mg to the aforementioned statute, i am to be In receipt of a notice proMing no flte opportunity to dispute such debt, whether the validity or any portion of it; therefore, i am requesting the validation of the debt under Tim 15 USC §1692g. Had I received this notice I woad have requested a signed and tad of a contrag for this account As I did not receive this notice I am now making this request. Therefore, since you proceeded with litigation without complying with the aforementioned statutes (and other statutes applicable), it is my intent to assert my rights and seek remedy in all aspects available to me, including filing a counterclaim or cross-complaint against all parties involved, along with the Answer to your Complaint, furthermore, I will file a separate complaint against you, and ail applicable parties involved with the respective State Bar Association. 1 hereby demand that this matter be dismissed on the grounds that you are in violation, pursuant to the aforesaid law and/or statutes, and applicable State law and/or statute, which parallels the Federal statute in definition and authority. You and/or your constituents must cease all collection efforts by your office or firm, if such violation is relevant In this case. If you are a law office or law firm who regularly practice debt collections on behalf of others, and have indeed acted in accord with the applicable statutes mentioned herein, please provide me with such substantial proof. I hope to resolve this matter amicably without the involvement of further litigation. Sincerely, JASON STOCKSLAGER and KRISTIN STOCKSIAGER UPS. POW $i8fVWDA hmy COM twjs 0 PACdg V poehup and DMiM CM*nmft IM mwtbe p hl MGM mdit ff, W01poff & Abramson L.L.P. .a 4660 Trindle Rd. 3rd Floor rq Camp Hill, PA 17011 c PMAL IMTOIME&I c Keep ills Mcdp t For InqurbL Po*rwk Here A MM inhmet %Mb ft a a or cent as11 A 0 s OCT ?0M M M VGftM rez,1V 2M ?@Kfftas=aaq ONO* UsINMW EIRM Wm IAa eRMW ?p+areo.serwasPKi" ..,l soft. Pimp OF SUVICS On, 10/00(0 I served the forgoing document dercnbed as: Response W Complaint, Pertaining to case no. 06-5307 on the kiev*ed party in fts action. By Iran X By placing a true dopey tbamof enclosed in a sealed envelope Addreoeed as fi&WS: wolpoff & Aknnson LLP 4660 Thadle Road, Suite 300 Camp Hill, PA 17011 x (BY MAIL) I am "readily f nnilim" with die normal practice of collection and processing mzcgxndmce thrmailing. Linder that practice itis dcpodwd . the U,& Posts Sei .ice orn the same day wish the postage thereon fully prepaid. VXA CERTMIM MAIL NO.: 7006 0$10 000a (- 33Y 3Y 7a nt }{arrisbuL ?(Cirjl QPn ylvan'ttx. Mate) in the ordinar, cowse ofbusiress. I am aware that on motion of the party served, a service is presumed invalid if postal cancellation date is niorc than one day after the date of deposit for matlling in affidavit. I Vla f i lyn OM - ) bOkn declare under penalty of perjury under the laws of the State of ?ex1Y15V vem i A d.at the above is t nm and cer ect. p DATE: O U p(p Sigaattue of Serve ANMM rr7 T -rr IT; i-rr '% SHERIFF'S RETURN - REGULAR r CASE NO: 2006-05307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION L L C VS STOCKSLAGER KRISTIN E ET AL SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE STOCKSLAGER KRISTIN E was served upon the DEFENDANT , at 2040:00 HOURS, on the 21st day of September, 2006 at 210 SOUTH 17TH STREET CAMP HILL, PA 17011 TJT)TC r`r KTTn 0 T(Ir V0T'A f'' T) 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 12.32 Postage .39 Surcharge 10.00 R. Thomas Kline .00 40.71? 09/22/2006 WOLPOFF & ABRAMSON /u/ouloG Sworn and Subscibed to By: before me this day Deputy eriff of A. D. SHERIFF'S RETURN - REGULAR CASE NO: 2006-05307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION L L C VS STOCKSLAGER KRISTIN E ET AL SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STOCKSLAGER JASON the DEFENDANT , at 2040:00 HOURS, on the 21st day of September, 2006 at 210 SOUTH 17TH STREET CAMP HILL, PA 17011 KRISTINE STOCKSLAGER by handing to ADULT IN CHARGE 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: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 R. Thomas Kline iv . vvy tDf6`!/p (P Sworn and Subscibed to before me this day 09/22/2006 WOLPOFF & ABRAMSON By: eputy Sh riff of , A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 2006-05307 Civil ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff CIVIL ACTION - LAW VS KRISTIN E STOCKSLAGER JASON STOCKSLAGER Defendant(s) PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. Respectfully Submitted, Date: b u Amy F. DZrho le # 7062 / Daniel F. Wolfson #20617 Philip C. . #8634 /" -arah E avid R. llowa#y #8 326- /S Tonilyn M. Chippie #8?$5?. Ehasz 86469 Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000 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. 159495198 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. 2006-05307 Civil ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS. CIVIL ACTION - LAW KRISTIN E STOCKSLAGER JASON STOCKSLAGER Defendant(s) CERTIFICATE OF SERVICE The undersigned does hereby certify that a copy of the foregoing praecipe was served this date by Regular Mail, Postage Pre-Paid on this l A-day of .2067. jCris4 S+0`V-51q?.4l Jason Stockslager 210 S 17TH ST CAMP HILL, PA 170110000 Amy F. Doyle #8U62 / Dana lfson #20617 Philip C. Warholic #86 1 / David R. alloway #8732 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000 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. 159495198 t? rv ° O -3 ? N