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HomeMy WebLinkAbout06-5824IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. OL -- ASSIGNEE OF CHASE MANHATTAN BANK ?? 210 SYLVAN AVENUE ENGLEWOOD CLIFFS NJ 07632- Plaintiff VS BRUCE C ENSOR 1024 TEAKWOOD LN ENOLA PA 17025 Defendant(s) CIVIL ACTION - LAW Filed on behalf of: Plaintiff, PALISADES COLLECTION,L.L.C. Counsel of record for this party: Date: Amy F. Doyle #81062 / Daniel F. Wolfson #20617 Philip C. 341 / Andrew C. Spears #87737 avid . Galloway #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. 159496758 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS BRUCE C ENSOR Defendant(s) :CIVIL ACTION - LAW NOTICE 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. 159496758 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS BRUCE C ENSOR Defendant(s) :CIVIL ACTION - LAW NOTICIA 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 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 la 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. 159496758 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. :No. C? 'S?'.2? et l?c.l„ ` ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS BRUCE C ENSOR :CIVIL ACTION - LAW Defendant(s) COMPLAINT 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, BRUCE C ENSOR, is an adult individual with a last known address of 1024 Teakwood Ln Enola, Cumberland County, PA 17025. 3. 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 Cmplt - WOR 1 W&A File No. 159496758 7. 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 $7,879.09. 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 $3,040.75. 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 $1,575.82. 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. 159496758 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter Judgment in favor of the Plaintiff and against Defendant in the amount of $7,879.09, plus interest in the amount of $3,040.75, plus attorney's fees in the amount of $1,575.82, plus costs of this action and any other relief as this Court deems just and reasonable. Respectfully Submitted, Date: Amy D. Doyle 87062 /Daniel F. Wolfson #20617 Phili ?rholic #86341 / Andrew C. Spears #87737 David . Galloway #873 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 CCP Cmplt - WOR W&A File No. 159496758 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 unsworn falsification to authorities. Date: + Utz Amy F. Doyl #87062 / Daniel F. Wolfson #20617 Philip C. W olic #86341 / Andrew C. Spears #87737 viG o73 onilyn M. Chippie #87852 asz #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 CCP Cmplt - WOR 4 W&A File No. 159496758 PLAINTIFF = 425230 ACCOUNT NUMBER = 4325160120293933 POOL ID = CHASAR CURRENT BALANCE = 7879.09 LSTPYMTDT = CO DATE = 20040730 DEBTOR #1 LAST NAME = ENSOR DEBTOR #1 FIRST NAME = BRUCE C DEBTOR #1 MIDDLE NAM = DEBTOR #1 ADDR 1 = 1024 TEAKWOOD LN DEBTOR #1 ADDR 2 = DEBTOR #1 CITY = ENOLA DEBTOR #1 STATE = PA DEBTOR #1 ZIP = 17025 DEBTOR #1 HOMEPHONE = 7177325967 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 = 1024 TEAKWOOD LN DEBTOR #2 ADDR 2 = DEBTOR #2 CITY = ENOLA DEBTOR #2 STATE = PA DEBTOR #2 ZIP = 170252046 DEBTOR #2 HOMEPHONE = 7177325967 DEBTOR #2 WORKPHONE = 0000000000 DEBTOR # SOCSEC = DEBTOR#2 DOB = DEBTOR = 4201867 ?i Irz i\J W C 7` C:l `f'? t , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, L.L.C. NO. 06-5824 ASSIGNEE OF CHASE MANHATTEN BANK, : Plaintiff V. : CIVIL ACTION -- LAW BRUCE C. ENSOR : Defendant. ANSWER WITH NEW MATTER NOW comes the Defendant, Bruce Ensor, by and through his counsel, Law Offices of Peter J. Russo, P.C., and answers as follows: 1. Defendant admits upon information and belief. 2. Defendant admits. 3. Defendant admits. 4. Defendant admits to using a charge card issued by Chase Manhatten Bank in making purchases. 5. Denied. Defendant never received statements of account from Plaintiff as shown in exhibit "A" and denies that he never objected to any accounting provided by Plaintiff. 6. Denied. Defendant never received the above-mentioned statement referenced in the averment and therefore denies it in its entirety. 7. Denied. Defendant denies that he owes this plaintiff any sum and specifically any sum stated on plaintiff's exhibit of statement of account. 8. Denied. Defendant denies he owes this plaintiff and therefore denies any interest accrual averred by plaintiff. 9. Denied. Defendant denies he owes this plaintiff and therefore denies any interest accrual averred by plaintiff. 10. Denied. Defendant denies he owes this plaintiff and therefore denies any attorney's fees being incurred. 11. Denied. Defendant denies he owes this plaintiff and therefore denies any attorney's fees being incurred. 12. Denied. Defendant denies he owes this plaintiff and therefore denies that any refusal to pay this plaintiff has been to the detriment of this plaintiff. 13. Denied. The defendant is unable to after reasonable investigation determine the veracity of this averment and therefore denies it. 14. This averment is a procedural matter and does not require a response by defendant. To the extent that a response is required, it is denied that the amount is within the jurisdictional amount required for compulsory arbitration. Defendant denies all other allegations of the Complaint that are not specifically admitted. WHEREFORE, Defendant requests that Plaintiff's Complaint be dismissed with prejudice and judgment be entered in his favor and against Plaintiff, plus costs of this action and such further relief that this Honorable Court may decree. NEW MATTER 15. Paragraphs 1-14 of Defendant's Answer with New Matter are incorporated herein by reference thereto. 16. Plaintiff has failed to set a claim upon which relief may be granted. 17. Plaintiff has failed to join an indispensable party. 18. Plaintiff has failed to mitigate its damages, if any. 19. Plaintiff may be barred in whole or in part by the applicable Statute of Limitations. 20. Plaintiff may be barred in whole or in part by the principle of res judicata. 21. Plaintiff's claim may be barred by estoppel, waiver and laches. 22. Plaintiffs claim may be barred by the Principles of Accord and Satisfaction. 23. Plaintiff's claim may be barred by the doctrine of payment. 24. Plaintiff voluntarily assumed the risk of the facts set forth in this Complaint and accordingly its claim is barred. WHEREFORE, Defendant, Bruce Ensor, respectfully requests the Court to enter judgment in favor of Defendant and against Plaintiff. Respectfully submitted, Law Offices Of Peter J. Russo, P.C. Scott A. Stein, Esquire Attorney ID No. 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 DATE: Li -F:? - a C VERIFICATION I, Bruce Ensor, verify that the statements made in the forgoing Answer with New Matter are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unsworn falsification to authorities. Dated: l Z !l<r PA! Bruce Ensor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, L.L.C. NO. 06-5824 ASSIGNEE OF CHASE MANHATTEN BANK, Plaintiff V. CIVIL ACTION -- LAW BRUCE C. ENSOR Defendant. CERTIFICATE OF SERVICE I hereby certify that I have on this day served a true and correct copy of the Defendant's Answer, upon the following person, in the manner indicated: U.S. Mail Wolpoff & Abramson, L.L.P Attorneys for Plaintiff 267 East Market Street York, PA 17403 DATE: G Scott A. Stein, Esquire CT. Ci -cry ..3. s ` .77 C7 ? T 'st r tyt =t7 a Andrew C. Spears, Esquire acs&wolpofflaw.com ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 (717) 303-6752 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, L.L.C., ASSIGNEE OF CHASE MANHATTAN BANK, Plaintiff vs. BRUCE ENSOR, Defendant AND NOW, TO WIT, this CIVIL ACTION - LAW NO. 06-5824 of December, 2006, comes the Plaintiff, Palisades Collection, L.L.C., Assignee of Chase Manhattan Bank, by and through its attorneys, the law firm of Wolpoff & Abramson, L.L.P., and files the following Reply to New Matter and avers as follows: 15. The statements in paragraph 15 of Defendant's New Matter constitute an incorporation paragraph to which no response is required. To the extent Plaintiff is required to answer, the same is denied, and strict proof is demanded at the time of trial. 16. Conclusion of law, no response required. If a response is required, LAW OFFICES WOLPOFF & ABRAMSON, LLP. ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION 46W TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303.6700 any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 17. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 18. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 19. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 20. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 21. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 22. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. 23. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION 4880 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717.303.8700 1. 24. Conclusion of law, no response required. If a response is required, any and all allegations or insinuations of wrongdoing on the part of Plaintiff are hereby denied. WHEREFORE, Plaintiff respectfully requests that this Honorable Court dismiss Defendant's New Matter with prejudice and enter judgment in favor of Plaintiff and against Defendant, along with the allowable costs of this action, and such further relief as the Court deems just and appropriate. Respectfully submitted, WOLPOFF & ABRAMSON, LLP Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 (717) 303-6752 Counsel for Plaintiff LAW OFFICES VOLPOFF & ABRAMSON, L.L.P. 4TTORNEYS IN THE PRAC77CE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303.6700 VERIFICATION The undersigned hereby states that he/she is the attorney for the Plaintiff, Palisades Collection, L.L.C., Assignee of Chase Manhattan Bank, who is located outside of this jurisdiction and in order to file the within document in an expedient and timely manner, he/she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Reply to New Matter are true and correct to the best of his/her 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 unsworn falsification to authorities. 13 1 aklc? Andrew C. Spears, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 (717) 303-6752 Counsel for Plaintiff LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. AT7DRNEYS IN THE PRACTICE OF DEBT COLLEC77ON 4880 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717-303.8700 •. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, L.L.C., CIVIL ACTION - LAW ASSIGNEE OF CHASE MANHATTAN BANK, Plaintiff vs. BRUCE ENSOR, NO. 06-5824 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Reply to New Matter upon Counsel for Defendant, by First Class Mail, Postage Pre-Paid, a copy thereof on this Wkay of December, 2006, to: Scott Stein, Esquire The Law Offices of Peter J. Russo, P.C. The Chelsea Building 3800 Market Street Camp Hill, PA 17011 CAAndrew C. pars, Esquire ID No. 87737 Wolpoff & Abramson, LLP Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 (717) 303-6752 Counsel for Plaintiff LAW OFFICES WOLPOFF & ABRAMSON, L.L.P. ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION 4660 TRINDLE ROAD THIRD FLOOR CAMP HILL, PA 17011 717.M-6700 r7 4? ; h?' - l ?_ `_ - _ \ . ? ? . ?.,? ?-? - ..r ? ..: ?.. ?T Y ? (e l 1_ ?3 s ?.? SHERIFF'S RETURN - REGULAR CASE NO: 2006-05824 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION L L C VS ENSOR BRUCE C RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ENSOR BRUCE C the DEFENDANT at 1722:00 HOURS, on the 23rd day of October , 2006 at 1024 TEAKWOOD LANE ENOLA, PA 17025 by handing to DONNA ENSOR, SPOUSE 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 18.00 Service 26.40 Postage .39 So Answers: Surcharge 10.00 R. Thomas Kline .00 54.79;/ 10/23/2006 WOLPOFF & ABRAMSON Sworn and Subscibed to By: r_. -11 before me this day Deputy Sheriff of A.D. ys PALISADES COLLECTION LLC ASSIGNEE OF CHASE MANHATTAN BANK V. BRUCE ENSOR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5824 CIVIL TERM PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David R. Galloway, Esq. , counsel for the PLANTIFF/defendant in the above action (or actions), represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $_12,496.56, The counterclaim of the defendant in the action is $ The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Scott Stein, Esquire & The Law Offices of Peter WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, David R. Gallo ay, Esq. ORDER OF COURT AND NOW, 1200 , in consideration of the foregoing petition, Esq., Esq., and ., are appointed arbitrators in the above captioned action (or actions) as prayed for. By the Court, EDGAR B BAYLEY r r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK : No. 06-5824 CIVIL TERM Plaintiff VS BRUCE C ENSOR Defendant(s) CERTIFICATE OF SERVICE : CIVIL ACTION - LAW The undersigned does hereby certify that a true and correct copy of the Petition for Appointment of Arbitrators was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on this .day of November, 2007. SCOTT STEIN 3800 MARKET ST. CAMP HILL, PA 170114327 Y Amy F. Doyle #8-k62 / Daniel F. Wolfson #20617 Philip C. Warholic #86 David R. allowa # Tonilyn M. Chippie #87 ar . 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. 159496758 SUN O ? J C v ? ? +v a 4L ? I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-5824 CIVIL TERM PALISADES COLLECTION LLC ASSIGNEE OF CHASE MANHATTAN BANK V. BRUCE ENSOR PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: David R. Galloway, Esq. , counsel for the PLANTIFF/defendant in the above action (or actions), represents that: 1. The above-captioned action (or actions) is (are) at issue. 2. The claim of plaintiff in the action is $_12,496.56. The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: Scott Stein, Esquire & The Law Offices of Peter Russo WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully submitted, David R. Gallo ay, Esq. ORDER OF COURT AND NOW, d , 200 7 , in consideration of the forego' g petition, Esq., and Esq., are appointed arbitrators in the above Esq/an cap cti ( or actions) as prayed for. rBov#t? CA EDGAR B BAYLEY t { ' C"7 M' Cpies .SOO ? I go l01 D?? PALISADES COLLECTION LLC, : IN THE COURT OF COMMON PLEAS OF ASSIGNEE OF CHASE MANHATTAN CUMBERLAND COUNTY, PENNSYLVANIA BANK, Plaintiff, V. : NO. 06-5824 CIVIL TERM BRUCE ENSOR, Defendant PRAECIPE FOR WITHDRAWAL AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: Ensor. Kindly withdraw the appearance of undersigned counsel on behalf of Defendant, Bruce Scott A. Stein, Esquire Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011 Ensor. Kindly enter the appearance of undersigned counsel on behalf of Defendant, Bruce NESTICO, DRUBY & HILDABRAND, LLP By: Scott A. Stein, Esquire Attorney I.D. No. 81738 Nestico Druby & Hildebrand, L.L.P. 840 East Chocolate Ave Date: Hershey, PA 17033 (717) 533-5406 (717) 533-5717 (facsimile) Attorney for Defendant rA ?? ?? °? ?, ?, ?, ,.?? ?,?? ? 5.. c; ?+ {.. ??`" ..p ' ?? ? ? PALISADES COLLECTION, LLC, PLAINTIFF V. BRUCE C. ENSOR, DEFENDANT MBNA AMERICA BANK, NA, PLAINTIFF V. BRUCE C. ENSOR, DEFENDANT MBNA AMERICA BANK, NA, PLAINTIFF V. BRUCE C. ENSOR, DEFENDANT FIA CARD SERVICES, NA, PLAINTIFF V. BRUCE C. ENSOR, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-5824 CIVIL TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 07-3663 CIVIL TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 06-2757 CIVIL TERM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-0847 CIVIL TERM ORDER OF COURT AND NOW, this 25? day of April, 2008, the appointment of a Board of Arbitrators in the above-captioned case, IS VACATED. Maria P. Cognetti, Esquire, Chairman, shall be paid the sum of $50.00. XMarie P. Cognetti, Esquire Court Administrator :sal Al1;vll6 o ?Ml By the Edgar B "Bayley, / 00 C\,3 LIJ kta C) C y? r -W .,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PALISADES COLLECTION, L.L.C., : Assignee of CHASE MANHATTAN : BANK, Plaintiff V. NO. 06-5824 BRUCE C. ENSOR CIVIL ACTION LAW Defendant STIPULATION AND AGREEMENT FOR ENTRY OF JUDGMENT AND NOW, comes Plaintiff PALISADES COLLECTION, L.L.C., by and through its attorneys, WOLPOFF & ABRAMSON, LLP, and Defendant BRUCE C. ENSOR, by and through his attorney, SCOTT STEIN, ESQUIRE, who stipulate and agree as follows: 1. Pa. R.C.P. 1037(c) provides that in all cases, the Court, on motion of a party, may enter an appropriate judgment against a party upon admission. 2. Defendant agrees and admits that Judgment should be entered against him in favor of Plaintiff in the amount of $11,117.24, plus costs of suit and interest accruing from date of judgment at the statutory rate of 6% per annum. 3. The parties agree that the Court, upon motion of Plaintiff, may enter Judgment pursuant to this Stipulation without issuance of a Rule to Show Cause, and without further proceedings or notice. By By Scott Stein David R. Gall to. aAttorney I.D. No. 73 Attorney I.D. 87236 840 E Chocolate Ave 4660 Trindle Rd., Ste. 300 Hershey PA 17033 Camp Hill, PA 17011 Attorney for Defendant Attorney for P intiff Date: Date: o UFi 119352207 IFA Pik 4-' . Qs,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA PALISADES COLLECTION, L.L.C., Assignee of CHASE MANHATTAN BANK, Plaintiff V. BRUCE C. ENSOR Defendants NO. 06-5824 CIVIL ACTION LAW ORDER OF COURT MAYS 02008 AND NOW, this L9 *day of /h ewe , 2008, upon consideration of the attached Stipulation and Agreement for Entry of Judgment, Judgment is hereby entered in favor of Plaintiff Palisades Collection, LLC and against Defendant Bruce C Ensor in the amount of $11,117.24, plus costs of suit and interest accruing thereafter at 6% per annum from date of Judgment. The Prothonotary is directed to enter and index this Judgment accordingly. BY THE COURT, for Plaintiff: .,""David R. Galloway, Esquire I.D. 87326 4660 Trindle Rd, Ste. 300 Camp Hill, PA 17011 for Defendant: Scott Stein, Esquire 840 E Chocolate Ave Hershey PA 17033 cop t?E4 "ImjLL ?'a4?o8 159496758 44 vv i 1 G j t p 191 ;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND PALISADES COLLECTION,L.L.C. ASSIGNEE OF CHASE MANHATTAN BANK Plaintiff VS. BRUCE C ENSOR Defendant (s) COUNTY, PENNSYLVANIA : No. 06-5824 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT To the Protonotary: Please mark the judgment in the above-entitled cause as paid and satisfied. Respectfully Submitted, By: Date: (0c, David R`Zlloway 87 ,306/Philip C. Warholic #86341 . Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PRAECV/PA176A FILE # 159496758 : 201 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. ASSIGNEE GF C# A .S C N A 111H A TT-A Al VS. BRUCE C ENSOR : No. 06-5824 CIVIL TERM CIVIL ACTION - LAW Defendant (s) CERTIFICATE OF SERVICE The undersigned does hereby certify that a true and correct copy of the Praecipe was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on r C1 . BRUCE C ENSOR 1024 TEAKWOOD LN ENOLA PA 17025-2046 David R. G'1`Philip C. Warholic #86341 $dT aN. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PACERP/PA176A FILE # 159496758 F'{LEL.- Ui`s"I C w?p?/ - -.1 It?'r'i tit t I THE DF 202-9 tr.' - p',,, 1: 4 b GJx?J ,? .v?? ?r 48.00 PQ A-rN M* 400'109 px? a3oo'19