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HomeMy WebLinkAbout02-3600PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) Pa.R.C.P. § 3103 to 3149 PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff VS. DAWN L. HENKEL Defendant(s) WAYPOINT BANK Gamishee(s) : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3600 Civil : CIVIL ACTION - LAW To the Prothonotary: ISSUE A WRIT OF EXECUTION IN THE ABOVE MATTER 1. Directed to the Sheriff of Cumberland County, Pennsylvania 2. against DAWN L. HENKEL , Defendant(s) 3. and against WAYPOINT BANK , Garnishee(s) 4. and index this writ (a) against Defendant(s) (b) against 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) NO LEVY-GARNISHMENT ONLY Serve interrogatories on garnishee at: 921 Calvary Road, Carlisle, PA 17013 5. Amount Due $4,065.52 Interest from 8729/01 $ 195.25 Total $4,260.77* *Plus writ costs Dated: August 1, 2002 Burton Neil, Esquire Attorney for Plaintiff NOTE: Under paragraph 1 when the writ is directed to sheriff of another county as authorized by Rule 3103(b), the county should be indicated. Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the count in which issued. Paragraph 3 above should be completed only if indexing of the execution in the county of issuance is desired as authorized by Rule 3104(a). When the writ issued to another county indexing is required as of course in that county. See Rule 3104(b). Paragraph 4(b) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See Rule 3104(c). The firm of Burton Neil & Associates, P.C. is attempting to collect a debt. BURTON NElL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff VS DAWN L. HENKEL Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW PRAECIPE TO TRANSFER JUDGMENT PURSUANT TO PA.R.C.P. 3002 TO THE PROTHONOTARY: Please enter judgment on behalf of plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, and against defendant, DAWN L. HENKEL in the sum of $4,265.52 less $200 credit, plus costs in accord with Pa.R.C.P. 3002 and attached are certified copies of the Perry County Judgment. . B~l~,~q., NElL & ASSOCIATES, P.C. f BY: Burton Neil, Esquire Attorney for Plaintiff AND NOW this c~ day of d ~ ,2002, judgment is entered on behalf of plaintiff, PORTFOLIO RECOVERY ASSOCIATES LLC, and against defendant, DAWN L. HENKEL, in the sum of $4,065.52 plus costs. Prothonotary Date: 07~08~2002 Time: 09:46 AM Page 1 of 1 41st Judicial District of PA, Perry County Branch ROA Report Case: CV-JP-2002-00440 Current Judge: UNASSIGNED PORTFOLIO RECOVERY ASSOCIATES vs. DAWN L HENKEL JP Trans User: CHARLES Date Judge 05/13/2002 07/05/2002 JP TRANS FILED EXIT 236 NOTICE TO DEFENDANT REAL DEBT $4265.52 Filing: JP Trans Paid by: BURTON NElL & ASSOCIATES Receipt number: 0000724 Dated: 5/13/2002 Amount: $.00 (Check) Filing: Certified Docket Entries Paid by: BURTON NElL,ESQ. Receipt number: 0001310 Dated: 07/08/2002 Amount: $10.00 (Check) UNASSIGNED UNASSIGNED UNASSIGNED BURTON NEIL & ASSOCIATES, P.C. · BY: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 ATTORNEY FOR: Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC Virginia Beach, VA 23462 Plaintiff VS DAWN L. HENKEL 398 Kings Hwy.-Lot 5, Marysville, PA 17053-9406 Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW Certification of Address and Affidavit of Non-Military Understanding that false statements herein are subject to penalty under 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment creditor and debtor. 2. The said defendant is not in the Military Service of the United States or its Allies or otherwise within the coverage of the Soldiers' and Sailors' Relief Act of 1940, as amended, is over 18 years of age and has civilian occupation. BIjR~O~NT~qE~, ~ & ASSOCIATES, P.C. By: Burton }qeil, Esquire ~- Attorney for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-3600 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES LLC, Plaintiff (s) From DAWN L. HENKEL, 398 KINGS HWY, LOT 5, MARYSVILLE, PA 17053-9406 (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 WAYPOINT BANK - SERVE INTERROGATORIES ON GARNISHEE AT: 921 CALVARY ROAD, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,065.52 Interest FROM 8/29/01 - $195. 25 Atty's Corem % Atty Paid $38.00 Plaintiff Paid Date: AUGUST 5, 2002 (Seal) REQUESTING PARTY: Name BURTON NEIL, ESQUIRE Address: THE TOWNE HOUSE 26 SOUTH CHURCH STREET PO BOX 356 WEST CHESTER, PA 19381-0356 Attorney for: PLAINTIFF Telephone: 610-696-2120 Supreme Court ID No. 11348 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonota~:y Deputy BURTON NElL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES LLC Plaintiff VS. DAWN L. HENKEL and WAYPOINT BANK Defendant Garnishee : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-3600 CIVIL : CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against Waypoint Bank, garnishee. BURTON NElL & ASSOCIATES, P.C. BY: ~ Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our finn is a debt collector. SHERIFF'S RETURN CASE NO: 2002-03600 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND - GARNISHEE PORTFOLIO RECOVERY ASSOCIATES VS HENKEL DAWN L And now HAROLD WEARY Cumberland County of Pennsylvania, to law, at 0015:50 Hours, as herein commanded all goods, chattels, moneys of the within named DEFENDANT HENKEL DAWN L hands, possession, 921 CALVARY ROAD on the 15th day of August , rights, debts, ,Sheriff or Deputy Sheriff of who being duly sworn according 2002, attached or control of the within named Garnishee credits, and , in the CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to LISA SIMMS (OPER3~TIONS SUPERVISOR) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 Sworn and subscribed to before me this ~-~,~W day of ~Oo~ A.D. Prdt~ono[ary true and made R Thomas Kline Sheriff of Cumberland County oo/oo/oooo By Deputy~eriff R. Thomas Kline, Sheriff, who being duly swom according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing 18.00 Poundage 1. ~ ~ Advertising Law Library .50 Prothonotary 1.00 Mileage 3.45 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Garnishee 9.00 73.38 Advance Costs: 150.00 Sheriff's Costs: 73.38 76.62 Refunded to Atty on 3/25/03 Swom and Subscribed to before me this J- v day of ~ 2003 A.D. ~,,~ tr~ pr6tffonotary So Answers; R. Thomas Kline, Sheriff C~ qo.~6t ~. 13~'t33