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HomeMy WebLinkAbout08-3081Our File No.: 156313 •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. ROBERT S SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: pg - 3o8 ) 0'm t der m 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) dial 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 0 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OF - 36; ! OA;;--t Tom. ROBERT S SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 Defendant. 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 ROBERT S SHORT, an adult individual residing at 1015 KENT DR MECHANICSBURG, PA 17050-7608. 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 $12,909.63. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is SEARS. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $12,909.63 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaa9 BY: Dated: 4/27/2008 David I RTES, P.C. Debt Our File No.: 156313 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 unWrn falsification to authorities. for Plaintiff DATE: 4/27/2008 LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 ROBERT S SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 STATEMENT OF ACCOUNT Debtor's Name: ROBERT S SHORT Account Number: 5121071847258369 Original Creditor: SEARS Balance Due: $12,909.63 Our File No.: 156313 EXHIBIT "A" ?.'r £? T s ? r ` 1 f/ . .... `r J s ? ? w c -< SHERIFF'S RETURN - REGULAR CASE NO: 2008-03081 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS SHORT ROBERT S SGT. JODY SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHORT ROBERT S the DEFENDANT , at 1040:00 HOURS, on the 19th day of May , 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013-7608 by handing to 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: Docketing Service Affidavit Surcharge 5122/bP 18.00 10.00 .00 10.00 .00 38.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/20/2008 APOTHAKER & ASSOCIATES By: J C j J ,,, ?4 h Deputy Sheriff of A. D. Our File No.: 156313 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. ROBERT S SHORT Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3081 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ROBERT S SHORT, in the default of an Answer, in the amount of $13,579.71 computed as follows: Amount claimed in complaint: $12,909.63 Amount Paid: - $(0.00) Interest from April 27, 2008 to 03/14/09 at the legal interest rate of 6.000 per annum $670.08 Costs $0.00 Attorney fees $0.00 TOTAL $13,579.71 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with P&R.Civ.P. 237.1 on the dates indicated on the Notices. I certify that Plaintiffs address as LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C 306, Mount Laurel, NJ 08054 and that Defendant, ROBERT S SHORT, last know address is 1015 KENT DR MECHANICSBURG, PA 17050-7608. APOTHAKE SOCIATES, P.C. Atto eys or Plaintiff A Law Firm g ed in pebt Collection By: Dated: 3/14/2009 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ROBERT S SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 LVNV FUNDING, LLC Plaintiff, VS. ROBERT S SHORT Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3081 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, Es q. at this telephone number: 215-634-8920 Our File No.: 156313 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. ROBERT S SHORT Defendant. Civil Action AFFIDAVIT OF NON-MILITARY 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 1015 KENT DR MECHANICSBURG, PA 17050-7608. e Data Center, located at 1600 Wilson We inquired with the web site of the Defens M power Boulevard, Suite 400, Arlington, VA 22209-2593, if D endant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defe se anpower Da -Center has sent back our inquiry indicated that the Defendant(s) is/are not in the mili David J. Apothaker Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3081 The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. 156313 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) Vs. ) ROBERT S SHORT ) To: ROBERT S SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3081 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 20, 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC 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 Request for Military Status Department of Defense Manpower Data Center 41 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAR-14-2009 06:38:13 < Last Name First/Middle Begin Date Active Duty Status Service/Agency SHORT ROBERT S 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. 01 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: hq://www.defenselink.mil/faq?is/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: FPOMJZVQ%P https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 3/14/2009 I CASE NO: 2008-03081 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF `PENNSYLVANIA: *ti COUNTY OF CUMBERLAND LVNV FUNDING LLC VS SHORT ROBERT S R MAY s o itioa SGT. JODY SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SHORT ROBERT S the DEFENDANT at 1040:00 HOURS, on the 19th day of May 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013-7608 by handing to ROBERT SHORT 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 10.00 _ Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 38.00 05/20/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: Jc Ct S before me this day Deputy Sheriff of , A.D. * M a AJ ? -c Our File No.: 156313 OF i- E L/ Jr-C.E elf THt PFt 0 THOr�� LVNV FUNDING, LLC i OTA1 IN THE COURT OF COMMON PLEAS OF Plaintiff :ilIBJEURLL-:Nop:0:;31/ . �CUMBERLAND COUNTY, PENNSYLVANIA 'ENNSYLVANIA - NO.: 08-3081.- vs. ROBERT S SHORT Defendant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; (2) against ROBERT S SHORT, defendant(s); and (3) against MEMBERS 1ST FCU 5000 LOUISE DRIVE MECHANICSBURG, PA 17055, Gamishee(s); (4) and index this writ in the judgment index (a) against ROBERT S SHORT, defendant(s), and (b) against MEMBERS 1ST FCU 5000 LOUISE DRIVE MECHANICSBURG, PA 17055, 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 $13579.71 Interest from March 24, 2009 $3968.22 Minus Payments made Plus Costs Total favt4 actu°'scia' `38.00 OF --19.5v 1y -$1200.00 $179.00 $16526.93 '�$ David J. Apothaker, Esquire Attorney for Plaintiff(s) Sa•a5 , 4 .Sb giti-scitted THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse. Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net LVNV FUNDING, LLC Vs. ROBERT S. SHORT WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-3081 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against ROBERT S. SHORT, 1015 KENT DRIVE, MECHANICSBURG, PA 17050 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of MEMBERS 1sT FCUGARNISHEE(S), as garnishee, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 - 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. (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. 1 (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $12,379.71 Plaintiff Paid Interest FROM MARCH 24, 2009 - $3,968.22 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Attorney Paid $159.50 Other Costs $179.00 Date: 7/7/14 (Seal) REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER SCIAN P.C. 520 FELLOWSHIP ROAD, C306 MT. LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE 9F' 'WE SHERIFF ii.:._i'sJ &HOT HOW) 14 Ail 10: ^(} CUMBERLAND COUNTY PENNSYLVANIA LVNV Funding LLC vs. Robert S Short Case Number 2008-3081 SHERIFF'S RETURN OF SERVICE 07/09/2014 02:57 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, North Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Sales Assistant, 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 July 11, 2014 to Robert s. Short at 1015 Kent Drive, Mechanicsburg, PA 17050-7608. IAM CLINE, DEPUTY SO ANSWERS, July 11, 2014 RONNY R ANDERSON, SHERIFF �c) CountySuite Sheriff, Telsosoft. Inc. Our File No.: 156313 ) LVNV FUNDING, LLC ) ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY vs. ) ) ROBERT S SHORT ) NO.: 08-3081 1015 KENT DR ) MECHANICSBURG, PA 17050-7608 ) Civil Action XXX -XX -4174 ) Defendant ) zi MEMBERS 1ST FCU cn Garnishee ) r CD Yi\\)iers F � INTERROGATORIES TO GARNISHEE —; --c TO: MEMBERS 1ST FCU, 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? 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)? nO 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? 00 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 A 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 Reggnitrothe exemption and the entity electronically depositing those funds on a recurring basis. Jut t 11 2014 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- theamountof-the-general exemption under-42PA.C.S.§8123?- If so, identify - each account. J o i n- account CXn C C` n 5 1839,93 9. How much is the value of any property in your possession belonging to the defendant(s)? n10.. 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: 1-)2,17 David J. Apothak- Esquire APOTHAKER SCIAN P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff Our File No.: 156313 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC Plaintiff vs. ROBERT S SHORT Defendant MEMBERS 1ST FCU Garnishee r F UT;`IONT fi 281! JUL Ct1t•1bEn L �, PENNS AN COUNTY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-3081 Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, RS 1ST FCU, dissolved. David J. .othaker, Esquire Attorney for Plaintiff k'fisci sop4A, clJu:t Jogsy9 c) a ggVB