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HomeMy WebLinkAbout06-6831IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION Plaintiff VS RENEE MORGAN Defendant(s) No. 01.- ler,3I CIVIL ACTION - LAW PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), RENEE MORGAN, for want of pursuant to the. District Justice Transcript. (X) Amount due $3,043.02 Less credits $ TOTAL. $3,043.02, plus interest and costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. ( X ) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. i Date: 0 0 A :$_ aniel F. Wolfson 0617 Philip C. Warh`olid #86341 drew C. Spears #87737 Davi a / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW, , 20-6-4e-, JUDGME E D AS VE. Prothonotary/Clerk, Civil ivision By: Deputy W&A File No. 151846850 ? ?:? ? <.r) ??... ? ? I`i [_,. t? ..... \1 ? ? ? ? ? COMMONWEALTH OF PENNSYLVANIA ir,oi INTV nP- CUMBERLAND Mag. Dist. No.: 09-1-03 MDJ Name: Hon RICHARD S. DOUGHERTY Address: 9 8 S ENOLA DR STE 1 ENOLA, PA Telephone: (717 ) 728-2805 17025 ATTORNEY FOR PLAINTIFF : NOLPOFF & ABRAMSON, LLP DAVID GALLOWAY 4660 TRINDLE RD, 3RD FL CAMP HILL, PA 17011 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUDGMENT PLTF NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS rCENTURION CAPITAL CORPORATION 4660 TRINDLE RD C/O NOLPOFF A ABRAMSON LCAMP HILL, PA 17011 J VS. DEFENDANT: NAME and ADDRESS rk-ORGAN, RENEE 706 ERFORD ROAD CAMP HILL, PA 17011 L J Docket No.: CV-0000211-06 Date Filed: 7/17/06 _ (Date of Judgment) 8/31/06 ® Judgment was entered for: (Name) CENTURION CAPITAL CORPORATION ® Judgment was entered against: (Name) MORGAN, RENEE 3 043 0T- -in the amount of $ ' ' Defendants are jointly and severally liable. Damages will be assessed on Date & Time This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 Portion of Judgment for physical damages arising out of residential lease $ of 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. 2)50- Date I c/e?rtifry? tnhat this is a true nd co /QCa Date My commission expires first Monday of Amount of Judgment $ 2,461.68 Judgment Costs $ 89.00 Interest on Judgment $ - Attorney Fees $ 492.34 Total $ 3,043.02 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ Magisterial District Judge containing the judgment. , Magisterial. District Judge uary, 20 AOPC 315-06 DATE PRINTED: 8/31/06 1:11:00 PM SEAL E t'fl?it Q ?a CD °, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION No. (DG -lvP3 ( C,t v L Plaintiff VS CIVIL ACTION - LAW RENEE MORGAN 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, Renee Morgan, above=named, is over 21 years of age; is last known to reside at 706 Erford Rd Camp Hill, County of Cumberland, Pennsylvania; is not in the military service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act and its Amendments. (Date D !?-? A e aniel F. Wolfson #20617 hili C. #863 Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff SWORN and SUBSCRIBED to before me this day of , 20 0 a _It+? Notary Public Na" Taw W & A File No. 151846850 O t W M. ftnbn NOW ?0 ?aemPdsn Twp., owftw*W 0=* Member, P1BMsybanie Anodeft Of Notaries C) 4= 0 Q 7 Q r li n-I _ W C7 ? c =. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION No. n4P _ 10 j>3 ( e('w cLc7?i2i-vj Plaintiff VS RENEE MORGAN Defendant(s) CIVIL ACTION - LAW CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Centurion Capital Corporation P.O. Box 1845 Rockville MD 20849 and certify that the last known address of the within Defendant(s) is: Renee Morgan 706 Erford Rd Camp Hill PA 17011 Date: I I I 11o I bi Am F. ??°vl?e #`8 ___ /Daniel F. Wolfson #20617 ilip C W /Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 151846850 C P E5 4? y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA / CENTURION CAPITAL CORPORATION No. - (00.3 (21,0-, Plaintiff VS RENEE MORGAN Defendant(s) TO: RENEE MORGAN 706 ERFORD RD CAMP HILL, PA 17011 CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT You re hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on `:2/Y16- in accordance with the provisions of Pa. R.C.P. 236. 1 ( ) 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 $3,043.02, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $2,461.68, attorney's fees in the amount of $492.34, interest in the amount of $0.00, plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspe ed by the Pennsylvania Department of Transportation. -? By: Prothonotary If you have any questions regarding this Notice, please contact the filing party. Date: (1/10/0, W&A File No. 151846850 inn (` Warhalic #81ri3414 Andrew C. Spears #87737 David R. Galloway #87326 / Tonilyn M. Chippie #87852 Sarah E. Ehasz #86469 / Robert N. Polas, Jr. #201259 Bruce H. Cherkis #18837 / Ronald S. Canter #94000 Ronald M. Abramson #94266 WOLPOFF & ABRAMSON, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 s ?. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 TO 3149 Plaintiff VS. RENEE MORGAN Defandant(s) : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : JUDGMENT NO. 06-6831 PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $ 3043.02. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against, RENEE MORGAN 706 ERFORD RD CAMP HILL PA 17011 Defandant(s); (3) and against M & T BANK located at 1 W HIGH ST CARLISLE PA 17013-2959 (4) And index this writ (A) against RENEE MORGAN Defandant(s) and (B) against, M & T 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 m & T 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: $ 3043.02 Interest From: 11/29/2006 To Be Determined At an interest rate of 6% per year Total: $ 3043.02 Plus costs & interest David R. Gallowa3V#87326/Philip C. Warholic #86341 Sarah E. 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 PABGAR/PABANK FILE # 151846850 i Fife-ass R&; CF THE PROT ?Wy 2001f UG 24 Pik 2: 08 ?.5o P o Al-t-f 14. 645 CSF 'a, so u $glo.as -PO ATTY #a. o© Oue Co 5o LL CO 345lo8(v RTIr ca -L9 (0(08 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6831 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENTURION CAPITAL CORPORATION, Plaintiff (s) From RENEE MORGAN, 706 Erford Road, Camp Hill, PA 17011 (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: M&T BANK, 1 W. High Street, Carlisle, PA 17013 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 $3,043.02 L.L. $.50 Interest from 11/29/06 at an interest rate of 6% per year -- To be Determined Atty's Comm % Atty Paid $46.25 Plaintiff Paid Date: 8/24/09 (Seal) Due Prothy $2.00 Other Costs C is R. Lon or of By: REQUESTING PARTY: Name AMY DOYLE, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Deputy Attorney for: PLAINTIFF Telephone: 866-253-0128 Supreme Court ID No. 87062 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy ????tir At ?st?bcrr??c? OFFICE OF '14E S"ERIrF F1LED-l.") r1CUP OF THE , „ { 17 Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 2OG9 SEP -2 P1112: 53 r „ I o,, 7!lµ Centurion Capital Corp. vs. Renee Morgan Case Number 2006-6831 SHERIFF'S RETURN OF SERVICE 08/28/2009 12:34 PM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 28, 2009 at 1234 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Renee Morgan, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Joan Srowl, Teller Supervisor, 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 her. The writ of execution and notice to defendant was mailed on August 31, 2009 to Renee Morgan at 706 Erford Road, Camp Hill, PA 17011. So Answers, R. Thomas Kline, Sheriff By 'r?/? Deputy Sheriff J J e IN THE COURT OF COMMON PLEAS CUMBERLAND I C-4 Plaintiff VS. i RENEE HORGAN Defendant (s) COUNTY, PENNSYLVANIA No. 06-6631 CIVIL ACTION - LAW INTERROGATORIES TO GARNISHEE TO: K & T BANK 1 W HIGH ST CARLISLE PA 17013-2959 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. 3. 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. PABINT/PABANK FILE # 151846850 J/ INTERROGATORIES TO-GARNISHEE DEFENDANT(S) - RENEE MORGAN ?A ,h 1 1. DEpi?SITORY 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 ide'n4fication numbers of those accounts, and the amount or amounts the Defend t(s) has in each account. If the Defendant(s) maintains an of these jointly with any o e? person, or persons, give their name and address. ll?? `l °° ^ o, lA. DIRECT DEPOSIT ACCOUNTS: Are any of the accounts you have listed above fix ~1?% deposit accounts? If yes, please state the identification numbers of those accounts. 10ro9 s 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. ??) 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. 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 defe dant(s) against you? 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. PABIN2/PABANK FILE # 151846850 41 v? 1 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 enc4brances or liens was recorded. If the Defendant(s) owns any personal property jointly with any person or persons, give names and address. 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). I??J 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 prop rty including its value and the interest of Defendant(s). A 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. 0 ' Melissa M. Peters M&T ank SEP 112M9 COPY David R. Galloway #87326/Philip C. Warholic #86341 Sarah E. Ehasz #86469/Robert N. Polas, Jr. #201259 Any 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 PARTUA/PARAW PTT_F. A 151R4FR50 SERVE 2004 S£P 1 4 PM 2: 35 CUA,t, ~i?!??'J x7 ? L}I r'?i?1 l?a l f CENTURION CAPITAL CORPORATION,: IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE MORGAN, ; DEFENDANT 06-6831 CIVIL TERM ORDER OF COURT AND NOW, this day of September, 2009, IT IS ORDERED that a hearing on the within claim for an exemption shall be conducted at 1:30 p.m., Wednesday, September 23, 2009, in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. By the C-hurt, ,1 Renee Morgan 706 Erford Road Camp Hill, PA 17011 ?Amy Doyle, Esquire 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 &T Bank 1 W. High Street Carlisle, PA 17013 Sheriff - ?Lu-ce-4L ?;-? ?11- :sal 1 izs r-Aa I 6CL I 4/l s/oF OF Ri' ' t `f-,Tmy 2009 SE 15 Ar 8, ? ~ar H "1 ! > n. CENTURION CAPITAL CORPORATION,: IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. RENEE MORGAN, DEFENDANT 06-6831 CIVIL TERM ORDER OF COURT AND NOW, this 2 day of September, 2009, following a hearing, on the claim for a statutory exemption of $698 for social security benefits on deposit in Account #9837936088 at M&T Bank, 1 West High Street, Carlisle, Pennsylvania, IT IS ORDERED that the exemption is applied against the $669.77 entered against that account. By th Gou i ? Renee Morgan 706 Erford Road Camp Hill, PA 17011 ./ David R. Galloway, Esquire 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 M&T Bank 1 W. High Street Carlisle, PA 17013 Edgar B. Bayley, J. Sheriff - P L-acecL t;6 Rc :sal 2 0!0? cFP 23 Pi' 2 - c5, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION Plaintiff NO. 06-6831 VS. RENEE MORGAN Defendant CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, M&T BANK, discontinued, upon payment of your costs only. Dated: v lit) i 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. 151846850 Respectfully Submitted, r {+{?i4_ 059 5.1' 26 ; 9., ?t i y 1 ' 21!,' c_v $8.0o PQ 1"1 co 44togus vg* aslo`to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION Plaintiff NO. 06-6831 vs. RENEE MORGAN Defendant CIVIL ACTION - LAW PRAECIPE TO SATISFY JUDGMENT Please mark the judgment in the above-entitled cause as paid and satisfied. Respectfully Submitted, By: Amy Do le he hili C?. Warholic #863 David R. Galloway #873 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 Cc: RENEE MORGAN 706 ERFORD RD. CAMP HILL, PA 17011 MB File No. 151846850 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENTURION CAPITAL CORPORATION Plaintiff NO. 06-6831 vs. CIVIL ACTION - LAW RENEE MORGAN Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that a true and correct copy of Praecipe To Satisfy Judgment, was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on this day of ???\LE r? ?fi-, 20 . RENEE MORGAN 706 ERFORD RD. CAMP HILL, PA 17011 l' Philip C. Warholic #8634 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 7-?,QV JV -.r Y Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY w OF 20101AR 31 P?12•3 UNTY CUW61-11 NSMLV Centurion Capital Corp. Case Number vs. Renee Morgan 2006-6831 SHERIFF'S RETURN OF SERVICE 08/28/2009 12:34 PM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on August 28, 2009 at 1234 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Renee Morgan, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 West High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Joan Srowl, Teller Supervisor, 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 her. The writ of execution and notice to defendant was mailed on August 31, 2009 to Renee Morgan at 706 Erford Road, Camp Hill, PA 17011. 09/14/2009 On Monday, September 14, 2009 at 1319 hours, a claim for exemption was received in this case. The original paperwork was taken to Court Administration. 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: $87.03 SO ANSWERS, March 30, 2010 RON R ANDERSON, SHERIFF B Sharon R. Lant (c) GourfySutte She?ff. I eloosofl. Wr,. .- 1% i ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-6831 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENTURION CAPITAL CORPORATION, Plaintiff (s) From RENEE MORGAN, 706 Erford Road, Camp Hill, PA 17011 (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: M&T BANK, 1 W. High Street, Carlisle, PA 17013 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 $3,043.02 L.L. $.50 Interest from 11/29/06 at an interest rate of 6% per year -- To be Determined Atty's Comm % Atty Paid $46.25 Plaintiff Paid Due Prothy $2.00 Other Costs Date: 8/24/09 (Seal) is R. Lon no By: Deputy REQUESTING PARTY: Name AMY DOYLE, ESQUIRE Address: MANN BRACKEN LLP 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 866-253-0128 Supreme Court ID No. 87062