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Home My WebLink About07-3440w APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I:D.#38423, 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. RODNEY E LYONS 17 WAYNE RD CAMP HILL, PA 17011-6663 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY No.. p'r _ ~~il ~l~ e,~; l`r~.,~ N(~TTC'F. You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action with twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 my proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONE. 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 LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I:D.#38423. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215)634-8920 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. RODNEY E LYONS 17 WAYNE RD CAMP HILL, PA 17011-6663 Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: d~, 3 y Sao ~ 1~.-- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, LVNV FUNDING LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is RODNEY E LYONS, an adult individual residing at 17 WAYNE RD CAMP HILL, PA 17011-6663. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiff s records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $3,721.79 from Apri123, 2004. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is PROVIDIAN FINANCIAL CORP. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,721.79 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm~n aged in Debt Collection BY: . Apothaker Dated: 5/29/2007 Our File No.: 97958 LVNV FUNDING LLC c/o Apothaker & Associates, P.C. • 2417 Welsh Road, Suite 21 #520 E Philadelphia, PA 19114 RODNEY E LYONS 17 WAYNE RD CAMP HILL, PA 17011-6663 STATEMENT OF ACCOUNT Debtor's Name: RODNEY E LYONS Account Number: 4254491800743359 Original Creditor: PROVIDIAN FINANCIAL CORP Date of Debt: Apri123, 2004 Balance Due: $3,721.79 Our File No.: 97958 EXHIBIT "A" -~ ~ lI n N 7TT c ~ o _ tt7~~ -- ~ - .... -n i-_r, 7 E'~ =C Y v\ ~ ~. ..~ LTt ~] ~~ ~ ~.-~~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-03440 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS LYONS RODNEY E MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LYONS RODNEY E the DEFENDANT at 1940:00 HOURS, on the 18th day of June 2007 at 17 WAYNE ROAD CAMP HILL, PA 17011 RODNEY LYONS by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 26.88 Affidavit .00 Surcharge 10.00 .00 4'1 S~U? ~ ~ 54.88 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 06/20/2007 APOTHAKER & ASSOCIATES By: ~ Deputy Sheriff A.D. Our File No.: 97958 APOTHAKER & ASSOCIATES, P.C. 2417 V~`elsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 LVNV FUNDING LLC Plaintiff, vs. RODNEY E LYONS Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-3440 CIVIL TERM Civil Action PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default .judgment in favor of plaintiff, LVNV FUNDING LLC and against Defendant, RODNEY E LYONS, for failure to answer or otherwise respond to the Complaint -Civil Action. The Complaint was served upon the defendants on June 18, 2007 by the CUMBERLAND Sheriff's Department. Copies of the proofs of service are attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on August 1, 2007, and also attached hereto. Assess damages in the amount of: (a) Balance: $3,721.79 (b) Interest from May 29, 2007 $50.75 TOTAL $3,772.54 APOTHAKER & ASSOCIATES, P.C. Attorneys fgr~'laintiff A Law Firm En~ae ~ Debt Colles~ia~ By: David J. Dated: 8/21/2007 Requesx for Military Status Department of Defense Manpower Data Center .Military Status Report Pursuant to the Servicemembers Civil Relief Act hops://www.dmdc.osd.miUscra/owa/scra.prc_Select AUG-21-2007 10:22:03 ~ Last Name'. First/Middle ;Begin Date Active Duty Status Service/Ageucy LYONS RODNEY 'Based on the information you have furnished, the DMDC does not '; possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. -1a~rn. ~.~tr-t~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility. for. military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers'. and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.miUfag/pis/PC09SLDR.htm1 1 of 2 8/21/2007 1:18 PM Our File No.: 97958 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney LD.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff LVNV FUNDING LLC Plaintiff, vs. RODNEY E LYONS 17 WAYNE RD CAMP HILL, PA 17011-6663 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY N0.07-3440 CIVIL TERM NOTICE OF INTENTION TO TAKE DEFAULT. TO: RODNEY E LYONS DATE OF NOTICE: August O1, 2007 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forkh against you. Unless you act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 S DAVID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423. SHERIFF'S RETURN - REGULAR CASE NO: 2007-03440 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS LYONS RODNEY E MICHAEL BARRICK She riff or .Deputy Sheriff.~if Cumberland County,Pennsyvaniat who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LYONS RODNEY E the DEFENDANT at 194Q00 HOURS, on the 18th day of June _, 2007 at 17 WAYNE ROAD CAMP HILL, PA 1?O11 by handing to RODNEY LYONS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the cantente thereof. 3h~ri~f"s Costs: Docke~.ing 18 , Ot7 Service 26.88 Affidavit .00 Surcharge 10.00. .00 54.88 Sworn and Subscibed to before me this day of , Sa Answers: -~ R. Thomas Kline 06J20/2007 APOTHAKER & ASSOCIATES By: Deputy She iff A.D. APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney LD.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff LVNV FUNDING LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 07-3440 CIVIL TERM RODNEY E LYONS ) Civil Action Defendant. ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENI~FSYLVANIA SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 17 WAYNE RD CAMP HILL, PA 17011-6663. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the inquiry indicated that the Defendant(s) is/are not in David J. Apothaker Attorney for Plaintiff Data Center has sent back our The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating fo unsworn falsification to authorities. z '~ *~ vA b 1.. ~'? ` r ~~: t: "_ .._, w C~ N N tJ"~ ~= n -3 ~~:~~i ~~,; -, ;-. -: t ? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS ~ Y TO: RODNEY E LYONS 17 WAYNE RD CAMP HILL, PA 17011-6663 LVNV FUNDING LLC Plaintiff, vs. RODNEY E LYONS Defendant. COURT OF COMMON PLEAS OF } CUMBERLAND COUNTY NO.: 07-3440 CIVIL TERM Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT _ JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esa. at this telephone number: 215-634-8920 830%7 /5~ C.u.+.Jrs ,e..~o+y a,~ U Our File No.: 97958 LVNV FUNDING LLC Plaintiff vs. RODNEY E LYONS - Defendant(s) OF RO H'ON0T R 20fi4 AUG -- I Phi 3: Oa CUMBERLAND COUNTY PENNSYLVANIA " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA - - - NO.: 07-3440 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; (2) against RODNEY E LYONS, defendant(s); and (3) against MEMBERS 1 ST FCU 1711 SPRING RD, CARLISLE, PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against RODNEY E LYONS, defendant(s), and (b) against MEMBERS 1 ST FCU 1711 SPRING RD, CARLISLE, PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s) as follows: Bank Attachment Only - All assets and accounts, including, but not limited to, bank accounts, brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $3772.54 Interest from August 30, 2007 $1539.82 Minus Payments made Plus Costs Total sac\ , c (1- ov Th c b\L♦ -$ $179.00 $5491.36 David J. Apothaker, Esquire Attorney for Plaint.ff(s) s, St) L. e )c)14 -R 69 3LzS ) ?3o(, eK THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net LVNV FUNDING LLC Vs. RODNEY E. LYONS. WRIT OF EXECUTION (Pa R.C.P. 3252) NO 07-3440 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against RODNEY E. LYONS, 24 SOUTH MARKET STREET, DUNCANNON, PA 17020 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1sT FCUGARNISHEE(S), as garnishee, 1711 SPRING ROAD, CARLISLE, PA 17013 - BANK ATTACHMENT ONLY- ALL ASSETS AND ACCOUNTS, INCLUDING BUT NOT LIMITED TO, BANK ACCOUNTS, BROKERAGE FIRM ACCOUNTS, STOCK'S, CD'S, INSURANCE, SAFETY DEPOSIT BOXES, ETC. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $3,772.54 Plaintiff Paid Interest FROM AUGUST 30, 2007 - $1,539.82 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $176.38 Other Costs $179.00 Date: 8/1/14 (Seal) REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER SCIAN P.C. 520 FELLOWSHIP ROAD C306 MT. LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F!LED-OFFICE i HE PROTHONOTARY 201ii AUG 14 AM I I: 45 CUMBERLAND COUNTY PENNSYLVANIA OFFICE OF THE .SHERIFF LVNV Funding LLC vs. Rodney E Lyons Case Number 2007-3440 SHERIFF'S RETURN OF SERVICE 08/12/2014 03:00 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 13, 2014 to Rodney E. Lyons at 24 S Market Street Duncannon, PA 17020. August 13, 2014 (c) CountySuite Sheriff, Teieosoft, b?c. M CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Our File No.: 97958 LVNV FUNDING LLC Plaintiff - vs.- -- RODNEY E LYONS 24 S MARKET ST DUNCANNON, PA 17020 XXX -XX -2599 Defendant MEMBERS 1 ST FCU Garnishee ) ) ) ) )- ) ) NO.: 07-3440 CIVIL TERM ) ) ) ) ) ) ) ) ) RECEIVED COURT OF COMMON PLEAS OF AUG 13 2014 CUMBERLAND COUNTY CI(ISweYS Civil Action INTERROGATORIES TO GARNISHEE TO: MEMBERS 1 ST FCU, Garnishee: 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. 1. At the time you were served or at any subsequent time did you owe the defendant(s) any money or were you liable to defendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(Cs) for any reason? 2. At the time you were served or at any subsequent time was there in your possession, custody, control or in the joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? 3. At the time you were served or any subsequent time did you hold legal title to any property of any nature owed solely or in part by the defendant(s) or in which the defendant held or claimed any interest? 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant(s) had any interest? 1C) 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to you or to any person or place pursuant to your direction or consent and what was the consideration thereof? 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? 7. If you are a bank or other financial institution, at the time you were served or 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 and the entity electronically depositing those funds on a recurring basis. 8. 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 the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general exemption under 42PA.C.S.:§8123? - Ifso,-identify- each account. , 19-1 4d „CO RECEIVED 9. How much is the value of any property in your possession belonging to the defendant(s)? AUG 13.2014 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: Co 6.4 David J. Apothaker, Esquire APOTHAKER SCIAN P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff 09/16/2014 TUE 841 FAX 856 780 1020 -).-0-4 members first 0002/003 • sEp 16 2.014 Our Fife No.: 97958 ) LVNV FUNDING LLC ) ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND CO UN'IY vs. ) ) RODNEY E LYONS ) NO.: 07-344() CIVIL TERM 24 S MARKET ST ) DUNCANNON, PA 17020 ) Civil Action r --- ---- Please contact our office if you need the ) Social Security Security number again, ) rrio3 =Fri ce) 1-rl Defendant )—< =---' co -MEMBERS 1 ST FC -1) C) := C Garnishee --i cri k.ID 44-Aswas 4-0 SUPPLEMENTAL INTERROGATORIES 'CO GARNISHEE TO: MEMBERS 1 ST FCU, Garnishee: You arc 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. 1 At the time you were served or at any subsequent time did you owe the delendant(s) any money or were you liable to delendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendant(s) any money or were liable to defendant(s) for any reason? Nx) 2. At the time you were served or at any subsequent time was there in your possession, custody, control or in thc joint possession, custody or control of yourself and one or more persons any property of any nature owned solely or in part by the defendant(s)? 3. At the time you were served or any subsequent time did you hold legal title to any property or any nature owed solely or in part by the defendant(s) or in which the defendant held or claimed any interest? 00 4. At the time you were served or at any subsequent time did you hold as fiduciary any propeity in which the defendant(s) had any interest? 0 09/16/2014 TUE 841 FAX 856 780 1020 -" members first 2003/003 5. At any time before or after you were served did the detendan stransfer or deliver any property to you or Lo any person OT place pursuant to your direction or consent and what was the consideration thereof? 1.30 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against you? 1&3 7. IC you are a hank or other financial institution, at the time you were served or any subsequent time did the delendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which arc 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 and the entity electronically depositing those funds on U recurrin • • 9-e5 5 A cYS' 8. If you arc 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 the thnds On deposit, not including any otherwise exempt funds, did not exceed the amount of the general exemption under 42PA.C.S.§8123? if so, identify each account. t• fl( CD 9. How much is the value of any property in your possession belonging to the defendant(s)? tt PC) 10. in the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: David J. A er, Esquire APOTHAKER SCTAN P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys (Or Plainti Our File No.: 97958 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC Plaintiff vs. RODNEY E LYONS Defendant MEMBERS 1 ST FCU Garnishee ILEI CI F10E -OF THE PROTNONO TAr `; 2014 OCT 14 P1112: 25 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-3440 CIVIL TERM Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, ME 1 ST FCU, dissolved. David J. A c.th er, Esquire Attorney for Plaintiff LTI" 1153`7 �' 3/aa33