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HomeMy WebLinkAbout06-6660IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. oG "44.40 ( 't ?T" Plaintiff VS CIVIL ACTION - LAW BARRY HOGAN Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), BARRY HOGAN , for want of pursuant to the District Justice Transcript. (X) Amount due $3,074.51 Less credits $ TOTAL $3,074.51, 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. ( ) 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 t:iEihasz f the notice is attached. Date: 7062 / Daniel F. Wolfson #20617 41 / Andrew C. Spears #87737 a #87326 onilyn M. Chippie #87852 86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherk is #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, , 20jDk, JUDG T IS S ABOVE. Protho tary/Clerk v 1 Divi n By: Deputy W&A File No. 156171955 COMMONWEALTH OF PENNSYLVANIA nni mrrv nc• CUMBERLAMID Mag. Dist. No.: 09-3-03 MDJ Name: Hon. SUSAN X. DAY Address: 229 KILL ST, BOX 167 MT. HOLLY SPRINGS, PA Telephone: (717 ) 486-7672 17065 PALISADES COLLECTION LLC. 4660 TRINDLE RD,FL3 C/O WOLPOFF & ABRAMSON CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: DEFAULT JUDGIMZNT PLTF Judgment: 0 Judgment was entered for: (Name) PALISADES COLLECTION LLC ® Judgment was entered against: (Name) ROGAN, BARRY in the amount of $ 3, 094.5 Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. F] Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 F1 Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment Judgment Costs interest on Judgment Attorney Fees Total $ 2,986.51 $ 88• $ - $ .00 $ 3,074.511 Certified Judgment Total $ 3,074.51 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGEMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. Z- ate , Magisterial District Judge I certify that this is a true d rre py of the reco d oce ings containing the judgment. Date , Magisterial District Judge 110-3:0 V My commission expires first Monday of January, 2010, AOPC 315-06 DATE PRINTED: 10/04/06 NOTICE OF IVLGCASE /TRANSCRIPT PLAINTIFF: NAME and ADDRESS rPALISADES COLLECTION LLC 4660 TRINDLE RD,FL3 C/O WOLPOFF & ABRAMSON LCAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rHOGAN, BARRY 310 WALNUT LANE CARLISLE, PA 17013 L J Docket No.: CV-0000143-06 Date Filed: 6/12/06 (Date of Judgment) 7/25/06 9:58:00 AIL SEAL C9 C c -TI C_. OCT ? ? 2006 NIA/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV?Ajlc?c , l.. l.. PALISADES COLLECTION,L.L.C. No. Plaintiff VS CIVIL ACTION - LAW BARRY HOGAN Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND The undersigned counsel, being duly sworn according to law, depose and say that I am the Attorney for the Plaintiff in the above-captioned matter, and that to the best of my knowledge, information and belief Defendant, Barry Hogan, above-named, is over 21 years of age; is last known to reside at 310 Walnut Ln Carlisle, County of Cumberland, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. Date: 14 /1)10 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Kimberly L. Eisennauer, Notary Public Hampden Twp., Cumberland County svly Commission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries Amy F. Doi a #87062 / Daniel F. Wolfson #20617 Phili C. olic #86341 / Andrew C. Spears #87737 av' oway #8732 Tonilyn M. Chippie #87852 Sm-ah- . 469 / 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 day of , 20? 146tary Public W & A File No. 156171955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION,L.L.C. No. CC- 4-? C,,:L74,LPn Plaintiff VS BARRY HOGAN Defendant(s) CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Palisades Collection,L.L.C. 210 Sylvan Avenue Englewood Cliffs NJ 07632 and certify that the last known address of the within Defendant(s) is: Barry Hogan 310 Walnut Ln Carlisle PA 17013 Date: G/ Amy Boyle 7062 / Daniel F. Wolfson #20617 Phi ' is #86341 / Andrew C. Spears #87737 avid R. G oway #873 onilyn M. Chippie #87852 ara asz obert 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. 156171955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAT.ICAI)RS COLLECTION,L.L.C. No. D1. Plaintiff VS CIVIL ACTION - LAW BARRY HOGAN Defendant(s) NOTICE OF ORDER, DECREE OR JUDGMENT TO: BARRY HOGAN 310 WALNUT LN CARLISLE, PA 17013 You a re hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on f2 _ in accordance with the provisions of Pa. R.C.P. 236. ( ) Decree Nisi in Equity ( ) Final Decree in Equity ( ) Judgment of ( ) Confession ( ) Verdict ( ) Default ( ) Non-suit ( ) Non-pros ( ) Arbitration Award (X) Judgment is in the amount of $3,074.51, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $1,800.06, attorney's fees in the amount of $360.01, interest in the amount of $826.44, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. By: P thonotary o' If you have any questions regarding this Notice, please contact the filing party. Date: 1< 6 Amy FVDe 062 / Danie l F. Wolfson #20617 Phili c #86341 / Andrew C. Spears #87737 avid a oway #8732 onilyn M. Chippie #87852 ar 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 W&A File No. 156171955 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff . S PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 PALISADES COLLECTION,L.L.C. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. JUDGMENT NO. 06-6660 CIVIL TERM BARRY HOJGAN PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Defendant(s) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $3,074.51. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,BARRY HOGAN located at 310 WALNUT LANE, CARLISLE, PA 17015-7821, Defendant (s); (3) and against, COMMUNITY BANKS located at 1196 WALNUT BOTTOM RD, CARLISLE, PA 17015, Garnishee (s); (4) and index.this writ (a) against, BARRY HOGAN , Defendant (s) and (b) against, COMMUNITY BANKS, 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) 310 WALNUT LANE CARLISLE; PA 17015-7821 All personal property of any nature located within the household or immediate vicinity of the Defendant(s) addrgas 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 COMMUNITY BANKS located at i 196 WALNUT BOTTOM RD, CARLISLE, PA 17015, 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 $3,074.51 Interest from 11/17/2006 To Be Determined At an interest rate of 6% per year Total $3,074.51 Plus costs* interest Date: ( a Amy F. Doyle #8 2 / Daniel Philip C. Warholic #863 avid R. Galloway #87326 Tonilyn M. Chippie #8785 asz Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 156171955 XXX-XX-4838 P 00 b$ 'b+ 6* O i?'1 C7 Lam, :- .. PA 9-4 w : AA ` ). WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-6660 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION LLC, Plaintiff (s) From BARRY ROGAN, 310 WALNUT LANE, CARLISLE, PA 17015-7821 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT'S ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMUNITY BANKS, 1196 WALNUT BOTTOM RD, CARLISLE, PA 17015 ALL ACCOUNTS INCLUDING BUT NOT LPAITED TO ALL SAVINGS, CHECKING AND OTHER ACCOUNTS, CERTIFICATES OF DEPOSIT, NOTES RECEIVABLES, COLLATERAL, PLEDGES, DOCUMENTS OF TITLE, SECURITIES, COUPONS AND SAFE DEPOSIT BOXES. and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $3,074.51 L.L. $.50 Interest from 11/17/06 at an interest rate of 6% per year Atty's Comm % Due Prothy $2.00 Atty Paid $46.25 Plaintiff Paid Other Costs Date: 8/23/07 (Seal) REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 T'RINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 kt?sR. Long, Prothonotary By: Deputy Attorney for: PLAINTIFF Itlephone: 717-303-6700 Supreme Court ID No. 87326 SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-06660 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND PALISADES COLLECTION L L C VS HOGAN BARRY And now KENNETH GOSSERT ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:03 Hours, on the 5th day of September, 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT rr?rvn xr nnring hands, possession, or control of the within named Garnishee COMMUNITY BANKS 1196 WALNUT BOTTOM RD , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JANICE MAYESKI (TELLER) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: So answers: Docketing .00 Service .00 P Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 0 0 V io%sw 7 09/ 20/2007 Sworn and Subscribed to before me this day of By A.D S R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor VOW of Calorr, ?d OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 10/04/07 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Sergeant Palisades Collection LLC vs Barry Hogan Writ No. 2006-6660 Civil Term ??o?os/o7 Property Claim Determination -r C c. t n Dear Sir, rte, cn Reference is made to Property Claim dated September 24, 2007, entered by Juanita R. Hogan, pertaining to Writ of Execution No. 2006-6660 Civil Term, Palisades Collection LLC -vs- Barry Hogan. R. Thomas Kline, Sheriff, has determined that the claimant, Juanita R. Hogan, in the above mentioned property claim, is the owner of the property set forth therein. So Answer r Thomas R. Kline, Sheriff By -? cc David Galloway, Atty for Pltff Barry Hogan, Defendant Juanita R. Hogan, Claimant PROPERTV CLAIM pIq Ijs D e- f o Ilecyl on VS g? v f.L c e, 1 ?D s' TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. o (D ?FCP 0 The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY _ VALUE CO& (.sue, _AA_ 7-CC2, 6 06 rile, C e _T 'd t' A/ 5 f 6 Y? ??i'? ? mp f ey' m.? 5_6 /.Sa!t ttI 6 a- ? d fiaStx"K"&_ Ackkl?' 1010 W4 -4 c,?.- e5w CLAIMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Date / IcR 1 /6) Claimau State of Pennsylvania County of Cumberland A 6' 4oq a6 being duly sworn according to law, deposes and says that the above list in the property claim correct and true. /1/101?m Swo an subscri bq!tobefbreme C t jcj9#V9W& BREWBAKEK 31oVjaJAUj Carlisle Boro. Cumberland County ) ( -7l l ly Commission Wres April 4, 2009 CV /I S I e , ,P 1 CJ cit" OS4ed fo c-,J 4dl vc? due" ?co,"C(? ?Y 3U (or SAC> ra-? CL)?4 bed ??SS SfcJ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6660 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION LLC, Plaintiff (s) From BARRY HOGAN, 310 WALNUT LANE, CARLISLE, PA 17015-7821 (1) You are directed to levy upon the property of the defendant (s)and to sell ALL PERSONAL PROPERTY OF ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF THE DEFENDANT'S ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN THE DOMINION AND CONTROL OF THE DEFENDANT WHEREVER IT IS LOCATED SHALL BE SUBJECT TO THE LEVY. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: COMMUNITY BANKS, 1196 WALNUT BOTTOM RD, CARLISLE, PA 17015 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. 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 $3,074.51 L.L. $.50 Interest from 11/17/06 at an interest rate of 6% per year Atty's Comm % Due Prothy $2.00 Atty Paid $46.25 Plaintiff Paid Other Costs Date: 8/23/07 (Seal) REQUESTING PARTY: Name DAVID R GALLOWAY, ESQUIRE Address: WOLPOFF & ABRAMSON, LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 s R. Long, Prothonotary By. A-R. 100&4 Deputy Attorney for: PLAINTIFF R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per Pennsylvania Rules of Court 3206 C0 Property Claim. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 121.49 Docketing 18.00 $ 28.51 Poundage 2.39 Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 10/15/07 Mileage 9.60 Surcharge 40.00 Levy 40.00 Post Pone Sale Garnishee 9.00 Postage TOTAL $ 121.49 ? / lb 4/6 1 So Answers; homZak ie, Sh riff au rew ` 'U ?Gr?3L; a b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Palisades Collection LLC Plaintiff V. Barry Hogan Defendant No. CI-06-6660 ANSWERS TO INTERROGATORIES FROM GARNISHEE TO: Susquehanna Bank 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) maintain any of these jointly with any other person, or persons, give their name and address. Yes, Defendant has a Free Checking account number xxxxxx5166 jointly held with Juanita R. Hogan. Juanita R. Hogan's address is 310 Walnut Lane, Carlisle, PA 17013-3738. The Free checking account had a balance of $1,557.29 after the general monetary exemption at time of service. Since time of service, the defendant has received direct deposits and the balance is in excess of the judgment amount. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. Yes, Defendant previously received a direct deposit from Yes Solutions described as payroll into the free checking account number xxxxxx5166. 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(s). Yes; however, funds sufficient for judgment remain available. 8. PROPERTY HELD AS A FIDICIARY: 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 the Defendant(s). No. 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorney 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 Answers. No. 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(s). No. 8. PROPERTY HELD AS A FIDICIARY: 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 the Defendant(s). No. 9. FEES OUTSTANDING TO GARNISHEE: Are there any attorney 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 Answers. No. VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Answers to Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: December 30, 2008 Catherine M. Bush Secretary and Legal Counsel Susquehanna Bank 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 s..? ?i _ _. c.? ----? -- ??. -?;? _} "J. ? . ?-4; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff vs. BARRY HOGAN vs. Defendant(s) NO. 06-6660 CIVIL ACTION - LAW SUSQUEHANNA BANK Garnishee Garnishee: SUSQUEHANNA BANK 26 N CEDAR ST, PO BOX 1000 LITITZ, PA 17543 PRAECIPE FOR JUDGMENT UPON ADMISSION To the Prothonotary: Please enter judgment in favor of the Plaintiff and against the Garnishee, SUSQUEHANNA BANK, in the amount of $1,557.29, as admitted in the answer to Interrogatories to be in the possession of Garnishee. Dated: ' T d Respectfully Submitted, 1 ilip C. Warholic #86341 / D vidR ay #X7 arah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 / (717) 303-6700 MB File No. 156171955 s Susquehanna Susquehanna Bancshares, Inc. 26 North Cedar Street Lititz, PA 17543-7000 Tel 717.626.4721 Fax 717.625.0331 December 30, 2008 Prothonotary's Office Cumberland County Courthouse 1. Courthouse Square Carlisle, PA 17013 Re: Palisades Collection LLC v. Barry Hogan Docket #: 06-6660 Dear Sir or Madam: Please find the enclosed Susquehanna Bank, formerly known as CommunityBanks, Answers to Interrogatories from the Garnishee in the above matter. Thank you for your cooperation. Sincerely, Catherine M. Bush Vice President and Associate Counsel CMB/veg Enclosures Cc: Jaimme Riano, Legal Assistant, w/enclosures Barry Hogan w/enclosures 15(o I q lq55 {+7' n?. 3n. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 06-6660 vs. BARRY HOGAN vs. Defendant(s) SUSQUEHANNA BANK Garnishee(s) NOTICE OF FILING JUDGMENT (X) Notice is hereby given that a JUDGMENT in the above captioned matter has been entered against you in the amount of $1,557.29 on a/A o9 T? (X) A copy of all documents filed with the Prothonotary in support of he within judgment is/are enclosed. OTHONO By: Deputy If you have any questions regarding this Notice, please contact the filing party: MANN BRACKEN LLC The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (717) 303-6700 (This Notice is in accordance with Pa.R.C.P. ` 236) iRo. 5-(N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION LLC Plaintiff NO. 06-6660 VS. CIVIL ACTION - LAW BARRY HOGAN Defendant PRAECIPE TO SATISFY JUDGMENT AGAINST GARNISHEE To the Prothonotary: Kindly mark the judgment entered against the Garnishee, Susquehanna Bank, in the above matter, satisfied upon payment of your costs only. Amy F. Doyl #87062 Philip C. W olic #86341 David R. Gallo ay #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (866) 253-0128 MB File No. 156171955 RLED-,OFFIr'E OF THE FROk HOIMOTARY 2009 JUN 10 PM 3: 3 3 $3,0o P D A rN Ci:,'tF aS 59-7 7 pj4 aa(. 55s 31 PRAECIPE FOR WRIT OF EXECUTION {MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 PALISADES COLLECTION,L.L.C. Plaintiff VB. BARRY HOGAN Defendant(s) : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA JUDGMENT NO. 06-6660 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $ 3074.51. (1) Directed to the Sheriff of CUMBERLAND -County, Pennsylvania; (2) against, BARRY HOGAN 310 WALNUT LANE CARLISLE PA 17015-7821 Defendant(s); (3) and against SUSQUEHANNA BANK located at 1196 WALNUT BOTTOM ROAD CARLISLE PA 17015 (4) And index this writ (A) against BARRY HOGAN Defendant(s) and (B) against, SUSQUEHANNA BANK Garnishee(s); ,Garnishee(s), as a lis pendens against the real property of the Defandant(s) in the name of the Garnishee(s) as follows: (Specifically describe ,property)***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of SUSQUEHANNA BANK , 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: $ 3074.51 interest From: 11/17/2006 To Be Determined At an interest rate of 6% per year Total: $ 3074.51 Plus costs & interest David R.'G lloway #87326 ilip C. Warholic #86341 Sarah E. Eh -z ert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP /-Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and,Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PABGAR/PABANK FILE # 156171955 6' Q Tt Po WT-H 1010-44 1101 . a5 A44. so ,• f3 • o ° ? --- Pp 4aL.oo t„*,Co 0 A al& So 3 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6660 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Plaintiff (s) From BARRY HOGAN, 310 Walnut Lane, Carlisle, PA 17015-7821 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SUSQUEHANNA BANK, 1196 Walnut Bottom Road, Carlisle, PA 17015 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. 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 $3,074.51 L.L. Interest from 11/17/06 at an interest rate of 6% per year -- to be Determined Atty's Comm % Atty Paid $211.74 Plaintiff Paid Date: 6/16/09 Due Prothy $2.00 Other Costs A, 2A? urtis R. Long, no (Seal) By: Deputy REQUESTING PARTY: Name DAVID R. GALLOWAY, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-01285 Supreme Court ID No. 87326 Sheriffs Office of Cumberland County R Thomas Kline` Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant Palisades Collection, LLC Case Number vs. 2006-6660 Barry Hogan SHERIFF'S RETURN OF SERVICE 06/25/2009 10:23 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 25, 2009 at 1022 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Barry Hogan, in the hands, possession, or control of the within named garnishee, Susquehanna Bank, 1196 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Frank Koser, Vice President, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on June 29, 2009 to Barry Hogan at 310 Walnut Lane, Carlisle, PA 17015. 2006-6660 Palisades Collection, LLC vs Barry Hogan So Answers, r?.ea.C R. homas Klime By puty Sher iferiff rv Q ?.? `r' c- -r ?r- ?- r '- O i. C_ CO JJ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA M PALISADES COLLECTION,L.L.C. Plaintiff VS. BARRY HOGAN Defendant(s) TO: SUSQUEHANNA BANK 1196 WALNUT BOTTOM ROAD CARLISLE PA 17015 No. 06-6660 CIVIL TERM CIVIL ACTION - LAW Answe%s lo INTERROGATORIES TO GARNISHEE 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. B. The term "Defendant(s)" means the individual(s) or entity against whom the Writ Execution was issued. C. "You" means the main office and all branch offices, representatives, employees and agents of your organization. D. By service of the Writ of Execution upon you, all property of the Defendant(s) subject to attachment which is in your possession, custody or control is attached, including all property of the Defendant(s) which comes into your possession thereafter. E. These Interrogatories are considered to be continuing and therefore should be modified or supplemented as you receive further or additional information. F. Where exact information cannot be furnished, estimated information is to be supplied. When an estimate is to be used, it should be identified as such, an explanation should be given as to the basis on which the estimate is made, and the reason the exact information cannot be furnished. G. Where knowledge or information in possession of a party is requested, such request includes knowledge of the party's agents, representatives, and attorneys. ss# XXX-XX- ? .? PABINT/PABANK FILE # 156171955 J/ y y INTERROGATORIES TO GARNISHEE DEFENDANT(S) - BARRY HOGAN 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 an of these jointly with any other person, or persons, give their name and address. 140. 1A. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above direct deposit accounts? If yes, please state the identification numbers of those accounts. Niq 2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) 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. 140. 3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the Defendant(s) have funds on deposit in an account in which funds on deposit, not including any otherwise exempt funds, did not exceed the amount of general monetary exemption under 42 Pa.C.S. 8123? If so, identify each account. No. 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(s) against you? No. 5. SAFE DEPOSIT BOX: 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. No. PABIN2/PABANR FILE # 156171955 4 1 79 KOKLO 6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or not the Defendant(s) own 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 encumbrances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. N 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(s). No. 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). No. 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. 140. COPY David Galloway #87326/Philip C. Warholic #86341 Sarah . Ehasz #86469/Robert N. Polas, Jr. #201259 Amy F. Doyle #87062 Mann Bracken LLP / Counsel for Plaintiff The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, P. C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: 866-253-0128 Fax: (717) 737-9051 PABIN3/PABANK FILE # 156171955 dir W. VERIFICATION I, Catherine M. Bush, verify that the facts set forth in these Interrogatories are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. § 4904) related to unsworn falsification to authorities. Dated: June 29, 2009 &-Z??- A , Catherine M. Bush, Secretary and Legal Counsel Susquehanna Bank 26 North Cedar Street Lititz, Pa 17543 (717) 625-6273 FlLFD w x;?r ()F 3f lc ?" "..ern";CRY 2 0Ill) JU.A 30 F 1,41 4 * 40 c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PALISADES COLLECTION, L.L.C. Plaintiff NO. 06-6660 CIVIL TERM VS. CIVIL ACTION - LAW BARRY HOGAN Defendant PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, SUSQUEHANNA BANK, discontinued, upon payment of your costs only. Respectfully Submitted, Dated:_ ?/Mh 4?? Amy F. y e 7062 Philip C. Warholic 6341 David R. Galloway #87326 Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 MANN BRACKEN LLP The Successor by Merger to Wolpoff & Abramson, LLP and Eskanos & Adler, PC Attorneys in the Practice of Debt Collection 4660 Trindle Rd., Suite 300 Camp Hill, PA 17011 (866) 253-0128 MB File No. 156171955 OF THE 2609 AUG -3 PH 1: 20 tjl .. CO Pp ?-rtN ? aaa?? Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor F! LED- ? iCE__ nr 7?.;Tw!-fitOTARY _ r [? . 2010 MAR 31 Phi 12: ?3 CUM Lj >? LINTY PENINSYLVANIA Palisades Collection, LLC vs. Barry Hogan Case Number 2006-6660 SHERIFF'S RETURN OF SERVICE 06/25/2009 10:23 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on June 25, 2009 at 1022 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Barry Hogan, in the hands, possession, or control of the within named garnishee, Susquehanna Bank, 1196 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Frank Koser, Vice President, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on June 29, 2009 to Barry Hogan at 310 Walnut Lane, Carlisle, PA 17015. 03/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.43 March 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF A ? B A 1 haron R. Lant 09 a39 5W SHERIFF'S OFFICE OF CUMBERLAND COUNTY (r,; Counh;Suite Sher f. i"e'eos ?t. Inc. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PALISADES COLLECTION, LLC, Plaintiff (s) From BARRY HOGAN, 310 Walnut Lane, Carlisle, PA 17015-7821 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: SUSQUEHANNA BANK, 1196 Walnut Bottom Road, Carlisle, PA 17015 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. 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 $3,074.51 L.L. Interest from 11/17/06 at an interest rate of 6% per year - to be Determined Atty's Comm % Atty Paid $211.74 Plaintiff Paid Date: 6/16/09 Due Prothy $2.00 Other Costs 2 /,A 440 C s R. Long n ary NO 06-6660 Civil CIVIL ACTION - LAW (Seal) By: Deputy REQUESTING PARTY: Name DAVID R. GALLOWAY, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-01285 Supreme Court ID No. 87326 alp FROM REGO"i . Mn TmWo ry whereof, t here unto set my Ae of said C+ou at Carts: !e, PE 4009 . ?ilfd.?•+• KtP1bI'?? I NIT bi,10-1