HomeMy WebLinkAbout07-7184IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
Plaintiff No.
" l
VS CIVIL ACTION - LAW
BETTY GEIBEL
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), BETTY GEIBEL , for want of pursuant to the District
Justice Transcript.
(X) Amount due $6,509.47
TOTAL $6,509.47, 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:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. • o' avid R. Galloway #87326
4T=' -7' . Ch1 Sarah E. Ehasz #86469
olas?Jr#22UT?9 / Ronald S. Canter #94000
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, , 2007-, JUDGME IS ENTERED AS ABO .
0 onotary/Clerk, Civil Division
By:
Deputy
W&A File No. 173828,830
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COMMONWEALTH OF PENNSYLVANIA.
rOIJNTY OF: CUMBEBI&ND
Mag. Dist. No.:
09-3-04
MDJ Name: Hon:
THOMAS A. PLACEY
Address: 104 S SPORTING HILL RD
MECHANICSBURG, PA
Telephone: (717 ) 761-8230 17050
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
rLVW FUNDING ASGN:SHERMAN AQUISITId
4660 TRINDLE BD, 3RD
C/O WOLPOFF A ABRAMSON
LCAMP HILL, PA 17011 J
VS.
DEFENDANT: NAME and ADDRESS
rGEIBEL, BETTY
809 ll[ANDY LANE
CAMP HILL, PA 17011
LVNV.FUNDING ASGN: SHZRMAlN AQUISITIO L_ J
4660 TRINDLE RD, 3RD Docket No.: CV-0000431-07
C/O NrOLPOFF A ABRAMSON Date Filed: 7/13/07
CAMP HILL, PA 17011 ~I
THIS IS TO NOTIFY YOU THAT:
FOR, PLAINTIFF (Date of _Judgment)
- - ?ludgment:- - -- - --- _ -
8/23/07
Judgment was entered for: (Name) LVNV FUNXIING ASGN: SHERUtAN AQUI
® Judgment was,antered against: (Name) GEIBEL, BETTY
in the amount of $ 6, 509.4
Defendants are jointly and severally liable.
Damaces will be assessed on Date & Time
F] This case dismissed without prejudice.
Amoun' of Judgment Subject to Attachment/42 Pa.C.S. § 8127
Portion )f Judgment for physical damages arising out of
residen ial lease $
Amount of Judgment $ 6,385,97
Judgment Costs $ 123.50
Interest on Judgment $ .00
Attorney Fees $ .0_0
Total $ 6,509.47
Post Judgment Credits $
Post Judgment Costs $
Certified Judgment Total $
ANY PARTY I AS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL Wf H 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 C rHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE
JUDGEMENT Ht LDER ELECTS TO ENTER.TJ.1E_ UDGMEHTIN. O rr o.F.cwmwP..LEAS..ALL.FUFIHER_P.: om.smun
COME FROM TF E 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 REOUEST FO i ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,
SETTLES, OR O -HERWISE COMPLIES WITH THE JUDGMENT.
0"41?? Date cr , Magisterial District Judge
I certify ttha this is a true a e recZ5 eedings containing the judgment.
0`4g U Date , Magisterial District Judge
My commission expires first Monday of January, 2010 SEAL
AOPC 315-06
DATE PRINTED: 8/23/07 10:45:00 AN
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
No.
Plaintiff
VS CIVIL ACTION - LAW
BETTY GEIBEL
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, Betty
Geibel, above-named, is over 21 years of age; is last known to reside at 809 Mandy Ln 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:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Phili C;C anc? is #86341 / David R. Galloway #87326
m 1y hippie #87 2 /Sarah E. Ehasz #86469
o as, Jr. #201239 /Ronald S. Canter #94000
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Brar di M. Moody, Notary Public
Hm"m Twp., Cumberiand County
My Co Twdssion E)Ores Nov. 30, 2010
Member, Pennsylvania Association of Notaries
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 l VOV(,Mb&- , 20 d7 .
&Did? J2 2&22?u
Notary Public
W & A File No. 173828830
to
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
Plaintiff
VS
BETTY GEIBEL
Defendant(s)
No.
CIVIL ACTION - LAW
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:
Betty Geibel
809 Mandy Ln
Camp Hill PA 17011
Date:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. Warholic #86341 / David R. Galloway #87326
2 / Sarah E. Ehasz #864169
ert N. Polas, Jr. #201259 / Ronald S. Canter #94:000
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. 17382,8830
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
No.
Plaintiff et.?L"
VS
BETTY GEIBEL .
Defendant(s)
CIVIL ACTION - LAW
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: BETTY GEIBEL
809 MANDY LN
CAMP HILL, PA 17011
You are hereby notified that the following ORDER, DECREE or JUDGMENT has been entered against you on
We= ag_ x.007 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 $6,509.47, plus costs.
(X) District Justice transcript of judgment in civil action in the amount of $5,916.24, attorney's fees in the
amount of $0.00, interest in the amount of $469.73, 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:
Prothonotary
If you have any questions regarding this Notice, please contact the filing party.
Date:
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Phili
n-CWarhutic 3414 David R. Galloway #87326
ni n ? 7852 /Sarah E. Ehasz #86469
Robert N. Polas, Jr. #201259 / Ronald S. Canter #94000
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. 173828830
J.
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
ASSIGNEE OF CITIBANK
Plaintiff
VS.
BETTY GEIBEL
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 07-7184-CIVIL
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 $6,509.47.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against,BETTY GEIBEL located at 809 MANDY LN, CAMP HEL, PA 17011, Defendant(s)
(3) and against, MEMBERS FIRST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013, Gamish*s);
(4) and index this writ
(a) against, BETTY GEIBEL , Defendant(s) and
(b) against, MEMBERS FIRST FCU, 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
MEMBERS FIRST FCU located at 1000 BRYN MAWR RD, CARLISLE, PA 17013, 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 $6,509.47
Interest from 11/29/2007 To Be Determined
At an interest rate of 6% per year
Total $6,509.47 Plus costs & interest
Date: C 6
Amy F. Doyle #8704 / 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. 173828830 XXX-XX-6846
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7184 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LVNV FINDING, LLC, assignee of SHERMAN
ACQUISITION, assignee of CITIBANK, Plaintiff (s)
From BETTY GEIBEL, 809 Mandy Land, 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:
MEMBERS FIRST FCU, 1000 Bryn Mawr Road, 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, 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 $6,509.47
L.L. $.50
Interest from 11/29/07 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Date: 1/15/08
(Seal)
Due Prothy $2.00
Other Costs
C . Long, Prot
By:
Deputy
REQUESTING PARTY:
Name PHILIP C. WARHOLIC, 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. 86341
r.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
ASSIGNEE OF CITIBANK
Plaintiff
VS
BETTY GEIBEL
Defendant(s)
No. 07-7184-CIVIL
CIVIL ACTION - LAW
710
INTERROGATORIES TO GARNISHEE
TO: MEMBERS FIRST FCU
1000 BRYN MAWR RD
CARLISLE, PA 17013
RECEIVED
JAN 21 2008
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 x(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 of 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, and 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 mquested, such request includes knowledge
of the party's agents, representatives, and attorneys.
W&A File No. 173828830 XXX-XX-6846
10 RECEIVED
INTERROGATORIES TO GARNISHEE JAN 2 2 2008
DEFENDAW(S) - BETTY GEIBEL
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 any of these jointly with any other person, or persons, give their name and
address.
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DeCeAJW
IA. 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.
nD
2. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the
defendant 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 areexempt 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.
n?
3. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the
defendant 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 monetary exemption under 42 Pa.C.S. 8123? If so, identify each account.
r , 2-0(o 337
olu
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 against you?
?u
5. SAFE DEPOSIT BOXES: 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.
11C
W&A File No. 173828830 XXX_XX-6846
6. REAL OR PERSONAL PROPERTY: At the time you were served or at any subsequent time, state whether or
not Defendant(s) owns 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 the encumbrances or liens was recorded. If the
Defendant(s) owns any personal property jointly with any person or persons, give names and address.
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.
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).
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?a/n?y(fees due and owing to the garnishee or the attorney for the garnishee for the preparation of the Answer.
0 0 `Date: (
F. Doyle #8706 / Daniel F. Wolfson #20617
Philip C. Warholic #8 341 / 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 R
Telephone: (717) 303-6700
Counsel for Plaintiff
E C E I V E D
JAN 2 Z 2008
W&A File No. 173828830 XXX-XX-6846
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1
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2007-07184 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LVNV FUNDING LLC
VS
GEIBEL BETTY
And now TIMOTHY BLACK
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0009:40 Hours, on the 18th day of January , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
GEIBEL BETTY
hands, possession, or control of the within named Garnishee
MEMBERS 1ST FCU 1166 WALNUT BOTTOM RD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BRIAN M. PETERS (BRANCH MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His .
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
/as'oP
.00
.00
.00
.00
.00-
.00
Sworn and Subscribed to
, in the
true
and made
So answerg:
R. Thomas Kline
Sheriff of Cumberland County
01/23/2008
before me this day of By I.,
Deputy Sheriff
A.D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC No. 07-7184-CIVIL
ASSIGNEE OF SHERMAN ACQUISITION
ASSIGNEE OF CITIBANK
Plaintiff
VS
BETTY GEIBEL
Defendant(s)
CIVIL ACTION - LAW
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
To the Prothonotary:
Kindly mark the attachment against the Garnishee, MEMBERS FIRST FCU, discontinued, upon payment of your
costs only.
Respectfully Submitted,
Date: o2ld?
Amy F. Doy e #8706 / Daniel F son #20617
Philip C. Warholic # 3 David?R-G Noway #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. 173828830
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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 10/30/08
.50
2.00
5.00
30.00
20.00
9.00 So Answers,
86.19 vol?
R. Thomas Kline, eriff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-7184 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LVNV FINDING, LLC, assignee of SHERMAN
ACQUISITION, assignee of CITIBANK, Plaintiff (s)
From BETTY GEIBEL, 809 Mandy Land, 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:
MEMBERS FIRST FCU, 1000 Bryn Mawr Road, 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, securites, coupons and safe deposit
boxes.
and to notify the gamishee(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 $6,509.47
L.L. $.50
Interest from 11/29/07 at an interest rate of 6% per year - To Be Determined
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: 1/15/08
(Seal)
REQUESTING PARTY:
Name PHILIP C. WARHOLIC, 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. 86341
b4
Curt' R. Long, Protho
By:
Deputy
52251
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•
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
LVNV FUNDING, LLC
Asstee j5herm?an A c%(,1'5? ion
ASSI NEE CITIBANK
Plaintiff
VS.
BETTY GEIBEL
Defendant (s)
COUNTY, PENNSYLVANIA
No. 07-7184-CIVIL
CIVIL ACTION - LAW
PRAECIPE TO SATISFY JUDGMENT
To the Protonotary:
Please mark the judgment in the above-entitled cause as paid and satisfied.
Respectfully Submitted,
By:
Date: David R. Gallo ay #87326 i i C. Warholic #8
Sarah E. Ehasz #86469 o er o as, r. X201259
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
PRAECV/PA176A FILE # 173828830
52261
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
LVNV FUNDING, LLC
ks5' ?oee. c?SY?e no,-) Ac%L, Sbbr)
ASSIGNEE O C1+i& an)(
VS.
BETTY GEIBEL
Defendant (s)
CERTIFICATE OF SERVICE
COUNTY, PENNSYLVANIA
No. 07-7184-CIVIL
CIVIL ACTION - LAW
The undersigned does hereby certify that a true and correct copy of the Praecipe
was served upon the individual(s) listed below by Regular Mail, Postage Pre-Paid on
INeiq -•
BETTY GEIBEL
809 MANDY LN
CAMP HILL PA 17011
David R. Galloway 326 clip C. Warholic #863
Sarah E. Ehasz # 6469/Ro er
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
PACERP/PA176A FILE # 173828830
A t`F-a
OF THc PRT" ION!OTAW
2009 JUN -4 PM 1: 07
CUM&I
PDASYNANIA