HomeMy WebLinkAbout08-0508IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
Plaintiff No. DS - '450B ?w i ( --firIA
VS CIVIL ACTION - LAW
JOHN R GINN
Defendant(s)
PRAECIPE FOR JUDGMENT
Please enter Judgment in favor of Plaintiff and against Defendant(s), JOHN R GINN , for want of pursuant to the District
Justice Transcript.
(X) Amount due $5,788.66
TOTAL $5,788.66, 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: ID `6
A y F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C. W -c #86341 / David R. Galloway #87326
, I.?ippie #8 / Sarah E. Ehasz #86469
o as, r. #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
ABOVE.
NOW, QaA c13 , 20 -08, JUDG 7'lm
Prot
h ,96otary/Clerk, iv' on
By:
Deputy
W&A File No. 178324504
COMMONWEALTH,bF ;PENNSYLVANIA
'tall INTY OF- CUMBERLAND
Mag. Dist. No.:
09-3-04
MDJ Name: Hon.
THOMAS A. PLACSY
Address: 104 S SPORTING HILL' °RD
KRI CRANICSBURG, PA
Teephone (717) 761-8230 17050
LVNV rMWING' LLC ASS:OBERMAN ACQ
4660 TRINDLB ROAD APT/STE 300
C/O VOLPOFF A ABRAMSON
CAMP HILL, PA 17011
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
?
rLvw rmwlNG LLC ASS: SHERMAN ACQ
4660 TRINDLE TOAD APT/STE 300
C/O NOLPOFF A ABRAMSON
SAMP HILL, PA 17011
J
VS.
.• DEFENDANT: NAME and ADDRESS
7l
rGINN,, JOHN R .: ,
4440 WOO ARD' DRIVE
MECHANICSBURG, PA 17050-2585
L_ J
Docket No.: CV-0000734-07
Date Filed: 10/25/07
THIS IS TO NOTIFY YOU THAT:
D_lFAt?I.T :. 4LT? -., (EM,
1XI Judgment was entered for: (Name) LV]l V IM DXNG LLC ASS: SffZRXAN A
F Judgment was entered against: (Name) Glll N JOHN R.
in the amount of $ 5, 788.6
Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
This case dismissed, without prejudice.
x ? Amount of Judgment Subject to Attachment/42' Pa.G.S. § 8127
Portion of Judgment for physical damages arising out of
residential lease $
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 JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES IF T
-JUDGMENT.HOLDEFLELECTS TOENTERTHE AM MENTJ?I THE.COUBT.PF COMM 14.PL BYL THEMAG STERIAL SSWUST u ;
COME FROM THE COURT OF COMMON PLEAS AND NO'FUFr HER PROCESS MAY'B Eb TRICT id 6 ?>•
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.
7 1? 0?
??1?ztb?t??Fro?•r
y,V; ti l ?' "sfo'sy
r
L a tl?Y d* r
f
DSlstriet';Judg?
Sf=AL`,
My commission expires first Monday of January, solo
AOPC 315-07
DATE PRINTED: 11/29/07 9:36:00 AN
Imy' ?l 0 2w
A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
No.
Plaintiff
VS CIVIL ACTION - LAW
JOHN R GINN
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, John R
Ginn, above-named, is over 21 years of age; is last known to reside at 4440 Woodward Dr Mechanicsburg, 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: &elv Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Phil' C. Warholic #86341
onilyn / David R. Galloway #87326
M. Chippie #87 / Sarah E. Ehasz #86469
o e 1259
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 ofja? t , 20OZ
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Brandi M. Moody, Notary Public
Hampden Up., Cumberland Courgy
W Commission E)pires Nov. 30, 2010
?Anjj,??k ?fl. - ?-Yyl_/
Notary Public
Member, Pennsylvania Association of Notaries
W &A File No. 178324504
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
No.
Plaintiff
VS
CIVIL ACTION - LAW
JOHN R GINN
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:
John R Ginn
4440 Woodward Dr
Mechanicsburg PA 17050-2585
Date: 1?a
Amy . D yle #87062 / Daniel F. Wolfson #20617
Ph' ' C. Warholi #86341 / David R. Galloway #87326
onilyn M. Chi ie 52 / Sarah E. Ehasz #86469
o ert 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. 178324504
r-a
' -r7
LTI
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
No.
Plaintiff
VS
CIVIL ACTION - LAW
JOHN R GINN
Defendant(s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: JOHN R GINN
4440 WOODWARD DR
MECHANICSBURG, PA 170502585
You are he by notified that the following ORDER, DECREE or JUDGMENT has been entered against you on
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 $5,788.616, plus costs.
(X) District Justice transcript of judgment in civil action in the amount of $5,665.16, attorney's fees in the
amount of $0.00, interest in the amount of $0.00, 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: g
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Phili 6341 / David R. Galloway #87326
onilyn . Chip pie #8 52 / Sarah E. Ehasz #86469
o as, r. 01259
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. 178324504
PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT)
P.R.C.P. 3101 to 3149
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN ACQUISITION
ASSIGNEE OF CITIFINANCIAL
Plaintiff
vs.
JOHN R GINN
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JUDGMENT NO. 08-508 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 $5,788.66.
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) against,JOHN R GINN located at 4440 WOODWARD DR, MECHANICSBURG, PA 17050-2585, Defendant
(s);
(3) and against, M & T BANK located at 1 W HIGH ST, CARLISLE, PA 17013, Garnishee (s);
(4) and index this writ
(a) against, JOHN R GINN , Defendant (s) and
(b) against, M & T 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) 4440 WOODWARD DR
MECHANICSBURG, PA 17050-2585
All personal property of any nature located within the household or immediate vicinity of the Defendant(s) address and all
other personal property within the dominion and control of the Defendant(s) wherever it is located shall be subject to the
levy.
ALSO: You are directed to attach the property of the Defendant (s) not levied upon in the possession of
M & T BANK located at 1 W HIGH ST,' 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 $5,788.66
Interest from 1/23/2008 To Be Determined
At an interest rate of 6% per year
Total $5,788.66 Plus costs & interest
Date: LA IL
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Philip C.`Grha ' 41 /David R. Galloway #87326
i yn M. Chippie #878 /Sarah E. Ehasz #86469
o e o as, r. #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. 178324504 XXX-XX-8619
C=3
d D _,I tz)
1
h
M
O\P
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-508 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 CITIFINANCIAL, Plaintiff (s)
From JOHN R. GINN, 4440 WOODWARD DR., MECHANICSBURG, PA 17050-2585
(1) You are directed to levy upon the property of the defendant (s)and to sell JOHN R. GINN, 4440
WOODWARD DR., MECHANICSBURG, PA 17050-2585 - ALL PERSONAL PROPERTY OF
ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF
THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN
THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS
LOCATED SHALL BE SUBJECT TO THE LEVY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of M&T BANK, 1 W HIGH ST., 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,
SECURITIES, COUPONS AND SAFE DEPOSIT BOXES.
GARNISHEE(S) as follows:
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 $5,788.66
L.L. $.50
Interest FROM 1/23/08 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Atty Paid $54.25
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: FEBRUARY 7, 2008
(Seal)
REQUESTING PARTY:
Name TONILYN M. CHIPPIE, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
Curtis . Long, Prothon
By: r
Deputy
4660 TRINDLE ROAD, SUITE 300
CAMP HILL PA 17011
Attorney for: PLAINTIFF
Telephone: 717-303-6700
Supreme Court ID No. 87852
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-00508 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
LVNV FINDING LLC
VS
GINN JOHN R
And now SHAWN HARRISON Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0015:00 Hours, on the 15th day of February-, 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
GINN JOHN R in the
hands, possession, or control of the within named Garnishee
M & T BANK 1 WEST HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
KRISTY LEHMAN MARTSON (SALES MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to Her .
true
and made
Sheriff's Costs: So answers:
P
Docketing .00
?
Service .00
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.00
0 0 ? ??.7o/p f
02/19/2
Sworn and Subscribed to
before me this day of By
A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 129.32
Docketing 18.00 20.68
Poundage 2.54
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 02/26/08
Mileage 17.28
Surcharge 40.00
Levy 40.00
Certified Mail
Post Pone Sale
Garnishee 9.00
Postage vS? o 7
TOTAL $ 129.32 So Answers;
R. Thomas Kline, Shenff
By Claudia A.. Brewbaker
'?2 os' ?1 L
G
10
0
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-508 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 CITIFINANCIAL, Plaintiff (s)
From JOHN R. GINN, 4440 WOODWARD DR., MECHANICSBURG, PA 17050-2585
(1) You are directed to levy upon the property of the defendant (s)and to sell JOHN R. GINN, 4440
WOODWARD DR., MECHANICSBURG, PA 17050-2585 - ALL PERSONAL PROPERTY OF
ANY NATURE LOCATED WITHIN THE HOUSEHOLD OR IMMEDIATE VICINITY OF
THE DEFENDANT(S) ADDRESS AND ALL OTHER PERSONAL PROPERTY WITHIN
THE DOMINION AND CONTROL OF THE DEFENDANT(S) WHEREVER IT IS
LOCATED SHALL BE SUBJECT TO THE LEVY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of M&T BANK, 1 W HIGH ST., 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,
SECURITIES, COUPONS AND SAFE DEPOSIT BOXES.
GARNISHEE(S) as follows:
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 $5,788.66
L.L. $.50
Interest FROM 1/23/08 AT AN INTEREST RATE OF 6% PER YEAR
Atty's Comm %
Arty Paid $54.25
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: FEBRUARY 7, 2008
(Seal)
REQUESTING PARTY:
Name TONILYN M. CHIPPIE, ESQUIRE
Address: WOLPOFF & ABRAMSON, L.L.P.
Curtis . ong, Proth ary
By:
Deputy
4660 TRINDLE ROAD, SUITE 300
IN THE COURT O
LVNV FUNDING, LLC
ASSIGNEE OF SHERMAN
ASSIGNEE OF CITIFINAIS
Plaintiff
VS
JOHN R GINN
Defendant(s)
PRAECIP
To the Prothonotary:
Kindly mark the attacl
only.
Date: 41(110(?
COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
No. 08-508 CIVIL TERM
ACQUISITION
CIVIL ACTION - LAW
TO DISCONTINUE ATTACHMENT EXECUTION
against the Garnishee, M & T BANK, discontinued, upon payment of your costs
Respectfully Submitted,
4-
Amy F. Doyle #87062 / Daniel F. Wolfson #20617
Phili t?# David R. Galloway #87326
tlyn M. Chippie 7852 / rah E. Ehasz #86469
o ert N. Polas, Jr.
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. 178324504
}
00
s° ? a
oo a
t? ,