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Home My WebLink About07-7717Our File No.: 11'1577 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. SAUNDRA J BAUGHMAN 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b7 - 7111 0,,, ?L NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within 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 may 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 ONCE. 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 notificacion. Hace 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 continuar la demanda en contra suya sin previo aviso o notificacion. 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 PARA 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. SAUNDRA J BAUGHMAN 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 SAUNDRA J BAUGHMAN, an adult individual residing at 15 N WALNUT ST MECHANICSBURG, PA 17055-3375. 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 Plaintiffs 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 $2,930.70. 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 $2,930.70 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A SOCIATES, P.C. Attorney or Plaintiff A Law Firm Eng a in Debt. Collection BY: David J. Dated: 12/18/2007 Our File No.: 111577 VERIFICATION David J. Apothaker, Esq. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. id J. Apothaker uev for Plaintiff DATE: 12/18/2007 1 LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 SAUNDRA J BAUGHMAN 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 STATEMENT OF ACCOUNT Debtor's Name: SAUNDRA J BAUGHMAN Account Number: 5542851000566489 Original Creditor: PROVIDIAN FINANCIAL CORP Balance Due: $2,930.70 Our File No.: 111577 EXHIBIT "A" c V ?:J SHERIFF'S RETURN - REGULAR CASE NO: 2007-07717 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS BAUGHMAN SAUNDRA J GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAUGHMAN SAUNDRA J the DEFENDANT at 2035:00 HOURS, on the 8th day of January , 2008 at 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 by handing to STEVE BAUGHMAN, SON 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: So Answers: Docketing 18.00 Service 9.60 Affidavit .00 J Surcharge 10.00 R. Thomas Kline l?ryrpt 3 7 ' 60 00 01/10/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: Axl? before me this day Deputy S iff of , A.D. , Our File No.: 111577 APOTHAKER &. ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. SAUNDRA J BAUGHMAN Defendant. NO.: 07-7717 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, SAUNDRA J BAUGHMAN, for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon the defendants on January 08, 2008 by the CUMBERLAND Sheriffs 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 February 8, 2008, and also attached hereto. Assess damages in the amount of (a) Balance: $2,930.70 (b) Interest from December 18, 2007 $253.41 TOTAL $3,184.11 APOTHAKER & ASSOC TES, P.C. Attorneys for ainti A Law Firm Engaged ' De Collection By: David J. Apothaker Dated: 10/1/2008 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: SAUNDRA J BAUGHMAN 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 LVNV FUNDING, LLC Plaintiff, VS. SAUNDRA J BAUGHMAN Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7717 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, Esc at this telephone number: 215-634-8920 ,0/x/08 • Our File No.: 111577 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. SAUNDRA J BAUGHMAN Defendant. NO.: 07-7717 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE wer Data Center has sent military. David J. Apothaker Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. 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 15 N WALNUT ST MECHANICSBURG, PA 17055-3375. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the back our inquiry indicated that the Defendant(s) The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Request for Military Status .. Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Pagel of 2 SEP-08-2008 08:55:28 Last Name First/Middle Begin Date Active Duty Status Service/Agency _T - BAUGHMAN SAUNDRA J 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. 0,21 )4. 14V 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 mil/faq//is/PC09SLDR html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmde.osd.miVscra/owa/scra.prc_Select 9/8/2008 Our File No.: 111577 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff LVNV FUNDING, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 07-7717 SAUNDRA J BAUGHMAN 15 N WALNUT ST MECHANICSBURG, PA 17055-3375 Defendant. NOTICE OF INTENTION TO TAKE DEFAULT TO: SAUNDRA J BAUGHMAN DATE OF NOTICE: February 8, 2008 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 forth 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: ti CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 /s/ David J. Apothaker 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 CASE NO: 2007-07717 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS BAUGHMAN SAUNDRA J GERALD WORTHINGTON' , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says the within COMPLAINT & NOTICE was served upon DA73GHMAN SAUNDRA J the DEFENDANT at 2 0 3 5 : 0 0 HOURS, on the 8th day of January ,20 at 25 N WALNUT ST MECHANICSBURG, PA 17055-3375 by handing to STEVE BAUGHMAN, SON a true and attested copy of . COMP MINT. & NOTICE together with and at the ;same time directing Ris attention to the contents` thereof. SSheriff's Costs': So Answers Docketing 18.00 Service 9.60 Affidavit .06 - Surcharge 20.00 R. Thomas :Kline .00 37.60 01/10/2008 ;APOTHAKER & ASSOCIATES Sworn and Subscibed to By': before me this day Deputy Shgfiff of r A.D 710 Our File No.: 111577 LVNV FUNDING, LLC IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. SAUNDRA J BAUGHMAN NO.: 07-7717 D fendant(s) q 4f,A. es PRAECIPE FOR WRIT OF EXECUTION WRIAP gloarn e ld pf 17aGe To the Prothonotary rri Issue a Writ of Execution in the above matter, w � (1) directed to the Sheriff of CUMBERLAND County; ?;cc-;) (2) against SAUNDRA J BAUGHMAN, defendant(s); and _ - (3) against WOODFOREST NATIONAL BANK 60 NOBLE BOULEVARD CARLISLE,PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against SAUNDRA J BAUGHMAN, defendant(s),and (b) against WOODFOREST NATIONAL BANK 60 NOBLE BOULEVARD 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 $3184.11 Interest from October 06, 2008 $891.38 Minus Payments made $0.00 Plus Costs $179.00 Total $4254.49 $a q . a Q � David J. Apothaker, Esquire l� 3 .5 (j,Attorney for Plaintiff(s) 15 9. 1 a Ric 3l .24 q DOr &Led WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 07-7717 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING,LLC Plaintiff(s) From SANDRA J. BAUGHMAN,952 GREENBRIAR ROAD,NEW BLOOMFIELD,PA 17068 (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: WOODFOREST NATIONAL BANK,60 NOBLE BLVD.,CARLISLE,PA 17013,ALL ASSETS AND ACCOUNTS,INCLUDING,BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. 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$3,184.11 Plaintiff Paid$ Interest FROM OCTOBER 6,2008-$891.38 Attorney's Comm. % Law Library$.50 Attorney Paid$159.10 Due Prothonotary$2.25 Other Costs$/94.1X) Date:JUNE 17,2013 David D. Buell,Prothonotary _ . Deputy REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER&ASSOCIATES, P.C. 520 FELLOWSHIP RD C306 MT. LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. SHERIFF'S OFFICE OF CUMBERLAND COUNTY cc: Jody S Smith Chief Deputy =- CD— Richard VVStewart _~ —— Solicitor oFFACSOFmsSVERIFF >`- ~nn '< (Zt) -� LVNV Funding LLC Case Number «� | � � 2ODT'7�17 Saundra JBaughman | SHERIFF'S RETURN OF SERVICE 06/21/2013 D9:37AM_Jamie DiMartle Deputy Sheriff,who being duly sworn according holaw,states that on June 21. 2013 at 0937 hours, attached as herein commanded all goods, chattels, rights,.debts, credits, and monies of the within named defendant, towit: Saundra J. Baughman, in the hands, possession, or control ofthe within named garnishee, Woodforest National Bank,60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, byhanding to Jennifer Peck, Retail Banker, 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 cf execution and notice to defendant was mailed on June 25, 2013 to Saundra J. Baughman at D52Greenbrior Road, New Bloomfield, PA17OG8. SO ANSWERS, � June�5. 2O13 h0mNYR ANDERSON, SHERIFF . ' ' (c)CountySufto Sheriff,m*osoft,*= N Our File No.: 111577 ) LVNV FUNDING, LLC ) ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) ) SAUNDRA J BAUGHMAN ) NO.: 07-7717 952 GREENBRIAR RD ) NEW BLOOMFIELD, PA 17068 ) Civil Action -z' `' XXX-XX-0819 ) r' 71 a Defendant ) C t-` -n E: w WOODFOREST NATIONAL BANK ) =c) Garnishee INTERROGATORIES TO GARNISHEE TO: WOODFOREST NATIONAL BANK, 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(s) for any reason? Ye S, ChkCUnq c�CC+ i332 �3zzd5 w�+h balance_ o� 4�oI B 5� e Ho[ d u¢,iv F Aerat bne rt In acct 2. At the time you were served or at any subsequent time as 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)? O 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? NO 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? 1\1 0 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? t40 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? N 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 ` r 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. yes, C iktkinc accoun+ 133234322-5 , i-t4i iasiz.00 d�posiked from Soci Secur�-ty 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? If so, identify each account. NI 0 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. i 3 Dated: � jQ( J 1 ) David J. Apothake , Esquire APOTHAKER&ASSOCIATES,P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856)780-1000 Attorneys for Plaintiff wwe-- 131-I1-tq IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW LVNV FUNDING, LLC Plaintiff vs. Case No. 07-7717 SUANDRA J BAUGHMAN Defendant VERIFICATION I, Amanda Martinez , hereby state that the facts above set forth are true and correct to the best of my knowledge, information and belief and that I expect to be able to prove the same at a hearing held in this matter. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 (relating to unsworn falsification to authorities). Date: June 26, 2013 41-■ ad-trU21.)9--- By: W. Jeffrey Levi, VP Woodforest National Bank 25231 Grogan's Mill Rd., Suite 100 The Woodlands, TX 77380 832-375-2898 —Phone 832-375-3071 —Fax STATE OF TEXAS COUNTY OF MONTGOMERY Before me, the undersigned authority, personally appeared Amanda Martinez on the 26th day of June, 2013 and stated that the foregoing is of their personal knowledge and is true and correct. �,PpY PUB; MELISSA BROMLEY Li ' 10 Notary PUbIIC,State 10x NOTARY PUBLIC IN AND FOR THE / M Commssior.Exres jonuary u 2015 STATE OF TEXAS ;:F- THE PROTf tONO lAk t Our File No.: 111577 APOTHAKER&ASSOCIATES, P.C. 2013 JUL 2 4 AM l f : 2 6 By: David J. Apothaker,Esquire CUMBERLAND COUNTY 520 Fellowship Road C306 PENNSYLVANIA PO Box 5496 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 07-7717 SAUNDRA J BAUGHMAN ) Civil Action Defendant ) WOODFOREST NATIONAL BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, WOO O ST NATIONAL BANK, dissolved. David J. A o ZkerEsquire, Attorney for Plaintiff Sz Q Gam- g3ssl � Il- SHERIFF'S OFFICE OF CUMBERLAND COUNTY Anderson 4,et COUP brit :r . . ay S Smith I nief Deputy 3 Vii `' " 1 i - Richard W Stewart Solicitor N LJ LA.nw 4, PENNSYLVANIA LVNV Funding LLC Case Number vs. Saundra J Baughman 2007-7717 SHERIFF'S RETURN OF SERVICE 06/21/2013 09:37 AM -Jamie DiMartle, Deputy Sheriff, who being duly sworn according to law, states that on June 21, 2013 at 0937 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Saundra J. Baughman, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, by handing to Jennifer Peck, Retail Banker, 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 June 25, 2013 to Saundra J. Baughman at 952 Greenbriar Road, New Bloomfield, PA 17068. 01/07/2014 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: $89.19 SO ANSWERS, January 07, 2014 RONNY R ANDERSON, SHERIFF sa Z-Z-�� 4 o's'iy 366 �/�