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"
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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,
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