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HomeMy WebLinkAbout08-0097Our File No.: 129098 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. MICHELLE HEAVNER 327 W GREEN ST MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: oe - q7 C i v t i -Ter P1 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 provisions 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. MICHELLE HEAVNER 327 W GREEN ST MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Of- 91 &? `7-;._ 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 MICHELLE HEAVNER, an adult individual residing at 327 W GREEN ST MECHANICSBURG, PA 17055. 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 $903.38. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is CITI-SEARS. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $903.38 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A SOCIATES, P.C. Attorne or Plaintiff A Law Firm En Zed Debt Collection BY: Dated: 12/21/2007 David Our File No.: 129098 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. David A?haker Attorney Plaintiff DATE: 12/21/2007 LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 MICHELLE HEAVNER 327 W GREEN ST MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: MICHELLE HEAVNER Account Number: 8060515671978 Original Creditor: CITI-SEARS Balance Due: $903.38 Our File No.: 129098 EXHIBIT "A" 00 PC) 0 w a YhJ c=:) c? Fri - 3`3 -71 t 8 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00097 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS HEAVNER MICHELLE TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HEAVNER MICHELLE DEFENDANT was served upon the , at 1404:00 HOURS, on the 11th day of January , 2008 at 327 W GREEN STREET MECHANICSBURG, PA 17055 MICHELLE HEAVNER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.60 Affidavit .00 Surcharge 10.00 //2 ajor, n- /`37 .00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/14/2008 APOTHAKER & ASSOCIATES By Dep(ity Sh&ri A.D. Our File No.: 129098 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 LVNV FUNDING LLC Plaintiff, VS. MICHELLE HEAVNER Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-97 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, MICHELLE HEAVNER, in the default of an Answer, in the amount of $967.57 computed as follows: Amount claimed in complaint: $903.38 Amount Paid: - $(0.00) Interest from December 21, 2007 to 05/14/09 at the legal interest rate of 6.000 per annum $64.19 Costs $0.00 Attorney fees $0.00 TOTAL $967.57 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, MICHELLE HEAVNER, last know address is 327 W GREEN ST MECHANICSBURG, PA 17055. Dated: 5/14/2009 APOTHAKER & S IATES, P.C. Attorneys or laintiff A Law Firm Engag T, Debt Collectioi David J. Apothaker By: OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MICHELLE HEAVNER 327 W GREEN ST MECHANICSBURG, PA 17055 LVNV FUNDING LLC Plaintiff, VS. MICHELLE HEAVNER Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } NO.: 08-97 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. Anothaker, Esq. at this telephone number: 215-634-8920 s?2o%? Our File No.: 129098 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 Plaintiff, VS. MICHELLE HEAVNER Defendant. Civil Action AFFIDAVIT OF NON-MI LITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : 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 327 W GREEN ST MECHANICSBURG, PA 17055. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if tilt, Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-97 David J. Apothaker Attorney for Plaintiff Data Center, located at 1600 Wilson is/are in any branch of the military. Data Center has sent back our inquiry 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. D of Defense Maaapower Data Center MAY-14-2009 09:31:59 Upm sears h nag the k&nnoon data boaks of the Department of Defense Manpower Data Center. based on the nEnnstion the you provided, the above is the come at of the individual as to al brencbes of the Mkory. May M. Sasv*-Dv=6 Director Depairtment of Demise Manpower Data Center 1604 W"dsoan BW , Suite 400 Arfangton, VA 22209-2593 'Ilse Defense b4napower Data Ceaater MMC) is an organzatim ` of the Department c(Defease, idw maWains the Defime Enrolment and E W Reporting System (DEERS) d +e why is the +' i source vfdda an a ty for ulkery medical care and other ei'ioildtp systems. The Department of Demme *m* supports the enforcenient of the Say bas Ciid RefiiefAct 150 USCS Appx §§ 501 et wql (SCRA.) =e dy the Soldiers! and Saints' CH RAdAnt of f 94. DWDC has issued hundreds of thousa a& of "does not possess any kfa motion indicating that the individini is aurarerady an active duty" respronses,; and has aqxsimced as and error rate. In the event the individual ralbrenced above, or my fatuity member, fiend. or representative asses in any annywr that the individaet is an active duty, at is awe edified to the promctiow of the SCRA, you are sko * enraged to obtain gather ves tiara of the person's active duty stntas by contacting a person"s Mary Service vk the "definsdWzxi" URL provided below.lf you have evidemd a the person is an nefive- daty and you £dl to obtain this addWonrl M mry Seaavice ification. provisions efthe SCRA maybe invoked against you. Ky ou obtain firther Eton about the person (e.g., an SSN, improved a aracy of DOB, a middle namel you can submit your request spin at this Web ske and we wit provide as new roe rti6cate for that gmyF. This response ruts current active duty stietus only. For histomd iifaxmabodn, plew coact the hlimry Service SCRA points of-caatarct. Sec; btly by : .mV c 'CD9SLI lt.lttmi WARM4Q This cartilicate was provided based on a name and Social Security aaunAw (SSN) provided by the rear. PravidiQg an erroneoius name or SSN call cause an effawous cerfficarte to be provide& Aspart"M-mumuffaw Wffitmy Status Report Parent to the S iceme s Civil Refief Act Our File No.: 129098 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. MICHELLE HEAVNER 327 W GREEN ST MECHANICSBURG, PA 17055 Defendant. NO. 08-97 NOTICE OF INTENTION TO TAKE DEFAULT TO: MICHELLE HEAVNER DATE OF NOTICE: February 13, 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: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 A ID 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 o CASE NO: 2008-00097 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS HEAVNER MICHELLE TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania,'who being-duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HEAVNER MICHELLE the DEFE MANT , at 2404 c 00 HOURS, on the 11th day of January , 2006 at 327 W GREEN STREET MECHANICSBURG, PA 17055 by handing to MICHELLE HEAVNER a, true and attested copy of COMPLAINT & NOTICE together with and at the 'same time directing Her attention to the contents thereof. Sheriff's Coasts ; Docketing ' 18.00 Service 9.60 Affidavit ,Q0 Surcharge 10.00 .00 37.64 Sworn and Subs4cibed to before me this day So Answers R. Thomas Kline 01/14/2008 APOTHAKER & ASSOCIATES By; x DepOty Sh&ri of .D. I FILED { -fir ' 'F ? , ??, ?, , .`?Y OF 21UC9 MAY 20 AN H: : rj 8 0 / y. o6 ?dL RIr? CK-4 13y81? R-4-- .2zsSr3a /UaI-ate- matL(, Our File No.: 129098 LVNV FUNDING LLC Plaintiff vs. MICHELLE HEAVNER Defendant(s) FROTI-10.1i01*; 2MPIP 11 Rti Os) CUMBERLAND COUNTY PENNSYLVAHIN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 08-97 PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, (I) directed to the Sheriff of DAUPHIN County; (2) against MICHELLE HEAVNER, defendant(s); and (3) against PENN STATE EMPLOYEES CU 1 CREDIT UNION PLACE HARRISBURG, PA 17110, Gamishee(s); (4) and index this writ in the judgment index (a) against MICHELLE HEAVNER, defendant(s), and (b) against PENN STATE EMPLOYEES CU 1 CREDIT UNION PLACE HARRISBURG, PA 17110, as Gamishee(s), as a lis pendens against the real property of the defendant(s) in the name of Gamishee(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 $967.57 Interest from May 20, 2009 $218.50 Minus Payments made Poundage(2%) Plus Costs Total 1,,s tn .CY3 (: k-1 ‘ a "k'`'‘ 3`). cob at3F 7 2c t, bo lt LI $29.06 $266.75 $1481.88 -bue David J. Ap aker, Esquire s SO Attorney for Plaintiff(s) alcs4 9R 34i '\-2..Asstr e2d,) icArS" wt&A --atreg WRIT OF EXECUTION and /or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08 -97 Civil COUNTY OF CUMBERLAND) CIVIL ACTION — LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING LLC Plaintiff (s) From MICHELLE HEAVNER, 327 W. GREEN STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PENN STATE EMPLOYEES CU, 1 CREDIT UNION PLACE, HARRISBURG, PA 17110 - ALL ASSETS AND ACCOUNTS, INCLUDING, BUT NOT LIMTED 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; (2) 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 $967.57 Interest FROM MAY 20, 2009 - $218.50 Attorney's Comm. % Attorney Paid $159.10 Other Costs $266.75 - POUNDAGE (2 %) - $29.06 Date: 3/17/14 REQUESTING PARTY.: Name : DAVID J. APOTHAKER, ESQ. Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD C306, P.O. BOX 5496 MOUNT LAUREL, NJ 08054 -5496 Attorney for: PLAINTIFF Telephone: 856 -780 -1000 Supreme Court ID No. Plaintiff Paid $ Law Library $.50 Due Prothonotary $2.25 David D. Buell, Prothonotary Our File No.: 129098 LVNV FUNDING LLC ) 201 ti APR 214 )2: 07 • Plaintiff CUMBERLAND 1UNTY COURT OF COMMON PLEAS OF PENNSYLNA! IA CUMBERLAND COUNTY VS . a0) C MICHELLE HEAVNER ) NO.: 08-97 327 W GREEN ST ) MECHANICSBURG, PA 17055 ) Civil Action XXX-XX-3591 ) ) t r, Defendant ) ) PENN STATE EMPLOYEES CU ) ) Garnishee ) INTERROGATORIES TO GARNISHEE TO: PENN STATE EMPLOYEES CU, 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. 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? No. 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)? Yes . 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? No . 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? No . 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? No . 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? If so, identify each account. Located four accounts : 0190XXXXXX- Yes, 9620XXXXXX-No, ' 8331XXXXXX-No, 8475XXXXXX-No. 9. How much is the value of any property in your possession belonging to the defendant(s)? See Attached. 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: Dav . Apothaker, Esquire APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attomeys for Plaintiff LVNV FUNDING LLC, Plaintiff VS. MICHELLE L HEAVNER Defendant and PA STATE EMPLOYEES CREDIT UNION, ANSWERS TO INTERROGATORIES IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI) Writ Docket No. 2014 -CV- 3478 -NT NO 08 -97 Account # 0190XXXXXX Michelle L Heavner Individual Total Account Balance: $ 216.36 Total Amount Available for Garnishment: $ 0.00 -$ 5.00* -$ 211.36 ** *$ 5.00 Membership Fee held in Regular Shares. * *$ 211.36 Exempt from attachment under 42 PA.C.S. 8123. Account contains less than $300 Monetary Exemption Account # 9620XX:XXX Michelle Heavner Individual Total Account Balance: $ 698.75 Total Amount Available for Garnishment: $ 605.11 -$ 5.00* -$ 93.64 ** *$ 5.00 Membership Fee held in Regular Shares. ** $93.64 Exempt from attachment under 42 PA.C.S. 8123. This amount is part of the $300 Monetary Exemption. Page 1. LVNV FUNDING LLC, Plaintiff VS. MICHELLE L HEAVNER Defendant and PA STATE EMPLOYEES CREDIT UNION„ Garnishee ANSWERS TO INTERROGATORIES IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIE Writ Docket No. 2014 -CV- 3478 -NT NO 08 -97 Account # 8331XXXXXX Justin Smith Joint Account Michelle Heavner Total Account Balance: $ 1,275.40 Total Amount Available for Garnishment: $ 538.19 -$ 5.00* *$5.00 Membership Fee held in Regular Shares. Account # 8475XXXXXX Courtney Richardson Joint Account Michelle Heavner Total Account Balance: $820.54 Total Amount Available for Garnishment: $ 538.18 -$ 5.00* $ 5.00 Membership fee held in Regular Shares. Total Garnishment Amount: $1,681.48 Page 2. Our File No.: 129098 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC Plaintiff vs. MICHELLE HEAVNER Defendant PENN STATE EMPLOYEES CU Garnishee FILED-Of 21 2814 JULJULTARPti 1: f9 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-97 Civil Action PRAECIPE TO SATISFY JUDGMENT AGAINST THE GARNISHEE TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, PEN;K STA E EMPLOYEES CU, satisfied. David J. Ap`bthaker, Esquire Attorney for Plaintiff OtvuA sct bc.,4 I (PS?)g 3o8 -)ss Shelley Ruhl Real Estale Deputy Matthew L. Owens Solicitor File # Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Latwick Sheriff F &0c(--q7u�� Jack Duignan Chief Deputy Michael W. Rinehart Assistant Chief Deputy Personal Property DOCKET SUMMARY Case Number Document Type Bankruptcy Case Number 2014 -CV -03478 -NT WRIT OF EXECUTION & INTERROGATORIES Received From: Date Received: 4/17/2014 Date Expires: PEOPLE ASSOCIATED WITH THE CASE Primary Defendant(s) Name: Primary Plaintiff(s) Name: Attorney: Firm: Attorney Phone: Attorney Address: Garnshee(s) Name: Type of Service: Address: PERSONAL PROPERTY Monies Levied: Date of Levy: District Justice: COMMENTS MICHELLE HEAVNER DOB: LVNV FUNDING LLC DOB: DAVID APOTHAKER APOTHAKER & ASSOCIATES, P.C. 856-780-1000 520 FELLOWSHIP ROAD, C306 MOUNT LAUREL, NJ 08054 PENN STATE EMPLOYEES CU - GARNISHEE DOB: PERSON IN CHARGE 1500 ELMERTON AVENUE HARRISBURG, PA 17110 INFORMATION Date of Sale: 4/18/14 SENT GARNISHMENT OUT WITH DEPUTIES 4/21/2014 DEPUTY CONWAY COMPLETED THE GARNISHMENT SENT RETURN AND WRIT TO STAY TO ATTY WRIT IN APRIL LETTER FILE 7/16/14 RECEIVED AFFIDAVIT OF SETTLEMENT COSTS FROM ATTY; 22 -.A RECOVERY IN THE SUM OF $1481.88 WAS RECEIVED 7/22/2014 RETURNED WRIT TO CUMBERLAND COUNTY PROTHY = MONEY MADE SENT COPY OF DOCKET SUMMARY TO DAUPHIN COUNTY PROTHY Cash Accounting Amount Date Added Category ID $200.00 4/18/2014 Deposit Agency 475496 ($87.00) 7/22/2014 Sheriff Costs 481829 ($19.35) 7/22/2014 Poundage 481830 ($10.00) 7/22/2014 State Fee 481831 ($83.65) 7/22/2014 Refund to Atty/Pltf 481832 Total Number of Rows: 5 ql4, 36 _ S►i C Balance Due: $0.00 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-97 Civil CIVIL ACTION — LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING LLC Plaintiff (s) From MICHELLE HEAVNER, 327 W. GREEN STREET, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: PENN STATE EMPLOYEES CU, 1 CREDIT UNION PLACE, HARRISBURG, PA 17110 - ALL ASSETS AND ACCOUNTS, INCLUDING, BUT NOT LIMTED 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; (2) 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 $967.57 Plaintiff Paid $ Interest FROM MAY 20, 2009 - $218.50 Attorney's Comm. oda Attorney Paid $159.10 Other Costs $266.75 - POUNDAGE (2%) - $29.06 .41AATN.)►n 0.0.t31.-1E- Date: 31•1SDate: 3/17/14 (Seal) Law Library $.50 Due Prothonotary $2.25 David D. Buell, Prothonotary REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQ. Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD C306, P.O. BOX 5496 MOUNT LAUREL, NJ 08054-5496 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. Deputy TRUE COPY FROTH RECORD In Testimony whereof, I here unto set my and and the seal ofsaid Co�u�at%�l�Pi�! This ____11 -day of JACICAI, Prothonotary a , qAccaP Our File No.: 129098 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC Plaintiff, vs. MICHELLE HEAVNER Defendant. 2 r: (;.'E 3: 2 PP vTY S �/V C0 1 ) COURT OF COMMON PLEAS ) CUMBERLAND COUNTY ) ) ) ) NO. 08-97 ) ) ) PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. Ap A A Law Fi By: v thak: orneys Enga r Scian P.C. for Plaintiff d in Debt: Collection David J. Apothaker, Esquire II [Ili 11,111111 I 1111 coo s . al(A ibuLoct1