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Home My WebLink About07-3840IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAI`IIA LVNV FUNDING, LLC Plaintiff VS No. 07 - 31 zv CIVIL ACTION - LAW MERVIN KUHN Defendant(s) PRAECIPE FOR JUDGMENT Please enter Judgment in favor of Plaintiff and against Defendant(s), MERVIN KUHN , for want of pursuant to the District Justice Transcript. (X) Amount due $3,803.31 TOTAL $3,61,3.31, plus interest and costs ( X ) I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain from the complaint. (X) Pursuant to Pa.R.C.P. 237 (Notice of Praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ( ) Pursuant to Pa.R.C.P. 237.1, I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occured and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. Date: 11 6 7 ?4-L ??kzl ' Amy F. Doyle #87062 / aniel F. Wolfson #20-617 Philip C. Warholic #86141 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 / Bruce H. Cherkis #18837 Ronald S. Canter #94000 / Ronald M. Abramson #94266 Wolpoff & Abrams6u, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff NOW,, , 204, JUDGME T IS AS ABOVE. Protho tary/Cler vil Di Sion By: Deputy W&A File No. 169929587 C cm CQn ° - r r r' : n COMMONWEALTH OF PENNSYLVANIA j COUNTY OF: CMMML AM Mag. Dist. No.: 09-3-02 MDJ Name: Hon. VIVIAN CONICS Address: PO BOX 155 27 N BIG SPRING NN VILL$, PA Telephone: (717) 776-3187 VIVIAN CONICS PO BOX 155 27 W BIG SPRING AVE NZWVXLL8, PA 17241 AVE 17241 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: rLVNP FO7fmING LLC NAME and ADDRESS 4660 TRINDLE ROAD APT/ST$ 300 VOLPOFF & ABRAKSON LLP I CA" HILL, PA 17011 DEFENDANT: VS. NAME and ADDRESS fkM, 3=71N 151 OAS FLAT ROAD NZWILLS. «? r« . L- "'-i ?IgI 4?-T') Docket No.: - 015-07 Date Filed: 2/22/07 (Date of Judgment) 4/10/07 THIS IS TO NOTIFY YOU THAT: Judgment: DgFAVLT JpDG1EMINT PLTF ® Judgment was entered for: (Name) LVNV FIDNDING LLC ® Judgment was entered against: (Name) SUM, XZRVIN in the amount of $ 3.803.3 P Defendants are jointly and severally liable. Amount of Judgment $ 3, 713.31 Damages will be assessed on Date & Time Judgment Costs F1 $ Interest on Judgment $ Attoey Fees $ • 00 This case dismissed without prejudice. Total $ 3,803.31 P Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 $ Post Judgment Credits $ Post Judgment Costs $ F1 Portion of Judgment for physical damages arising out of -- --- residential lease Q -""'--_--- Certified Judgment Total $ 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. /0107 Date 7J ` Magisterial District Judge I certify that this is a true and correct copy of th re ord th proceedings containing the judgment. Date ` Magisterial District Judge My commission expires first Monday of January, 2012 SEAL AOPC 315-06 DATE PRINTRD; 4/10/07 10.03.00 A11[ J J a G ° 0 ,t r r` C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC No. _y.?/L?? 07 - 3f? etc?? l l Plaintiff VS MERVIN KUHN Defendant(s) CIVIL ACTION - LAW AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND am the Atto The undersigned counsel, being duly sworn according w Iknowledge, nformation and belief De endant,tMervin Plaintiff in the above-captioned matter, and that to the best y lat Kuhn, above-named, is over 21 years of age; is last knoto reside at United St1 Oak Fts Alles oewv r illerwoen itof the Cumberland, Pennsylvania; is not in the military service of the Servicemembers Civil Relief Act and its Amendments. Date: 4T* Amy F. DZar e # 062 / Daniel F. Wolfson 0617 C. ho l c #8 David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah Ehasz Cherk86469 Robert N. Polas, Jr. #201259 / Bruce 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 COMMONWEALTH OF PENNSYLVANIA Telephone: (717) 303-6700 Notaria Seal "Counsel for Plaintiff Kimberly L. Eisennauer, svo>ary Public Hampden Twp., Cumberland County My Commission Expires Nov. 17, 2009 Member, Pennsylvania Association of Notaries 2 SWORN and SUBSCRIBED to before me this day of Notary Public W & A File No. 169929587 CZ GSt L3 "? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC No. 07 - Plaintiff (..:to L VS CIVIL ACTION - LAW MERVIN KUHN Defendant(s) CERTIFICATE OF RESIDENCE PA. R.C.P. 236 I hereby certify that the precise address of Plaintiff is: Lvnv Funding, Llc 15 South Main Street Greenville SC 29601 and certify that the last known address of the within Defendant(s) is: Mervin Kuhn 151 Oak Flat Rd Newville PA 17241 Date: r v7 / / Amy F. Doyle #87062 / aniel F. Wolfson #20617 Philip C. Warholic #86341 / 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. 169929587 ;- rin '° y } a r-n CD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC Plaintiff VS MERVIN KUHN Defendant(s) TO: MERVIN KUHN 151 OAK FLAT RD NEWVILLE, PA 17241 No. 07-.3 Pit) n' `T CIVIL ACTION - LAW NOTICE OF ORDER, DECREE OR JUDGMENT Yo are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on L 2& 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 $3,803.31, plus costs. (X) District Justice transcript of judgment in civil action in the amount of $3,133.34, attorney's fees in the amount of $0.00, interest in the amount of $579.97, 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 If you have any questions regarding this Notice, please contact the filing party. Date: ([9 j b ? Llwz Amy F. Doyle #8f 0f, Daniel F. Wolfson #20617 Philip C. Warholic 6341 / 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 W&A File No. 169929587 Counsel for Plaintiff =7V A tPp6thonotary, PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) P.R.C.P. 3101 to 3149 LVNV FUNDING, LLC ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF CITI-SEARS Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MERVIN KUHN Defendant(s) JUDGMENT NO. 07-3840 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: Please issue the Writ of Execution in the above-captioned matter, in the amount of $3,803.31. (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) against,MERVIN KUHN located at 151 OAK FLAT RD, NEWVILLE, PA 17241, Defendant(s) (3) and against, CITIZENS BANK located at 665 N EAST ST, CARLISLE, PA 17013-2004, Garnishee(s); (4) and index this writ (a) against, MERVIN KUHN , Defendant(s) and (b) against, CITIZENS BANK, 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) ***GARNISH ONLY*** You are directed to attach the property of the Defendant(s) not levied upon in the possession of CITIZENS BANK located at 665 N EAST ST, CARLISLE, PA 17013-2004, 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 $3,803.31 Interest from 06/26/2007 To Be Determined At an interest rate of 6% per year Total $3,803.31 Plus costs & interest Date: aJ d? Amy F. Doyl #8706 Daniel F. Wolfson #20617 Philip C. Warholic #86341 / David R. Galloway #87326 Tonilyn M. Chippie #87852 / Sarah E. Ehasz #86469 Robert N. Polas, Jr. #201259 Wolpoff & Abramson, L.L.P. Attorneys in the Practice of Debt Collection 4660 Trindle Road, Suite 300 Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff W&A File No. 169929587 XXX-XX-8339 a c -? 00 o$ M -v v 4z s 0Ua ' g? ro, C41 -c WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3840 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING, LLC, assignee of SHERMAN ACQUISITION, assignee of CITI-SEARS, Plaintiff (s) From MERVIN KUHN, 151 Oak Flat Rd., Newville, PA 17241 (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: CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013-2004 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, 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 $3,803.31 L.L. $.50 Interest from 6/26/08 at an interest rate of 6% per year - To be Determined Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: 3/24/08 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Curtis . ong, Pro ary By: Deputy Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062 SHERIFF'S RETURN - GARNISHEE CASE NO: 2007-03840 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND LVNV FUNDING LLC VS KUHN MERVIN And now NOAH CLINE ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0013:30 Hours, on the 28th day of March , 2008, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT KUHN MERVIN hands, possess=ion, or control of the within named Garnishee CITIZENS BANK 565 N EAST ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to MELISSA AUMAN (TELLER) 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 Service Affidavit Surcharge Sworn and Subscribed to before me this , in the true and made S r .00 .00 .00 R. Thomas Kline .00 Sheriff of Cumberland County 0000 ..i y/o3/off L 03/31/2008 day of By Deputy Sheriff A.D IN THE COURT OF OF CUMBERLAND COUNTY, PA CIVIL DIVISION LVNV Funding LLC assignee of Sherman Acquisition assignee of Citi-Sears Plaintiff(s), VS. Mervin Kuhn Defendant(s), and Citizens Bank of Pennsylvania, Garnishee. 07-3840 Civil Term ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS 1 to 9) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories: The Garnishee Citizens Bank, Pa. states that it maintains no deposit accounts in the name of the defendant, Mervin Kuhn; accordingly, no funds are being held subject to this writ of execution. it COMMONWEALTH OF PENNSYLVANIA COUNTY OF ALLEGHENY SS: Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Sandra Brain who being duly sworn according to the law deposes and says that she is the Operations Clerk, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief Sandra Brain Sworn and subscribed before me this day of 2008. NOWN SW ManayJ NoftryPubk CltyOf Pftburyh, A ftheny County My Conxnisebn EVM J* 20.2008 riber. Pennsylvania As/odatt of imm r IN THE COURT OF UNITED STATES DISTRICT OF CUMBERLAND COUNTY, PA CIVIL DIVISION LVNV FUNDING LLC ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF CITI-SEARS, Plaintiff(s), vs. MERVIN KUHN, Defendant(s), vs. Citizens Bank of Pennsylvania, Garnishee. 07-3840 Civil Term Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 2600 One Commerce Square Philadelphia, PA 19103 - 7098 (215)-564-8142 K' Certificate of Service I, Sandra Brain, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 1- day of 2008. Wolpoff & Abramson, LLP, Amy F. Doyle, Esq. 4660 Trindle Road, Suite 300 Camp Hill„ PA 17011 - "? /' A"" Sandra Brain ? ? ?"? 1. ? ° . c _? r,':c? ? ::? Yl ?..? _.? , ?:, _... ,, .. ._. _, f: < ? .?.- _ c?a:t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING, LLC ASSIGNEE OF SHERMAN ACQUISITION ASSIGNEE OF CITI-SEARS Plaintiff VS MERVIN KUHN Defendant(s) No. 07-3840 CIVIL TERM CIVIL ACTION - LAW PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION To the Prothonotary: Kindly mark the attachment against the Garnishee, Citizens Bank, discontinued, upon payment of yourcosts only. Respectfully Submitted, Date: (b C. Warholic #86341 / arch E. Ehasz 06469 / Robert N. Polas, Jr. #201259 Mann Bracken LLC The Sucoessor by Merger to Wolpoff & Abramson, L.L.P. and Eskanos & Adler, P.C. 4660 Trindle Road, Suite 300, Camp Hill, PA 17011 Telephone: (717) 303-6700 Counsel for Plaintiff File No. 169929587 C= ryy ?_ V ^J^1 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Milage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee Advance Costs: 150.00 86.19 18.00 63.81 1.69 Refunded on 11/05/08 .50 2.00 5.00 30.00 20.00 9.00 86.19 l??a Nl n ?' So Answers, -0001-r Aeovaac `?t7 R. Thomas Kline, Sheriff o By JOAO-/ a Z fi .E d S Z 8VW 8002 Vd ',l i F JJW3HS ?- jO Gk 4 L 3i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 07-3840 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING, LLC, assignee of SHERMAN ACQUISITION, assignee of CITI-SEARS, Plaintiff (s) From MERVIN KUHN, 151 Oak Flat Rd., Newville, PA 17241 (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: CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013-2004 All accounts including but not limited to all savings, checking and other accounts, certificates of deposit, notes receivables, collateral, pledges, documents of title, securites, 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 $3,803.31 L.L. $.50 Interest from 6/26/08 at an interest rate of 6% per year - To be Determined Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: 3/24/08 (Seal) Due Prothy $2.00 Other Costs ?: 44i? Curtis W long, Pio-7 By: Deputy REQUESTING PARTY: Name AMY F. DOYLE, ESQUIRE Address: WOLPOFF & ABRAMSON, L.L.P. 4660 TRINDLE ROAD, SUITE 300 CAMP HILL, PA 17011 Attorney for: PLAINTIFF Telephone: 717-303-6700 Supreme Court ID No. 87062