HomeMy WebLinkAbout08-3234
Our File No.: 160168
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.
BRAD WIEST
14 GRAY PL
MECHANICSBURG, PA 17055-5650
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: aa- 3aaq
0 ,iv! l T mn
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.
BRAD WIEST
14 GRAY PL
MECHANICSBURG, PA 17055-5650
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: d 32 3 Y etv?
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is LVNV FUNDING LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite
21 #520, Philadelphia, PA 19114.
2. Defendant(s) is/are BRAD WIEST, an adult individual residing at 14 GRAY PL
MECHANICSBURG, PA 17055-5650.
3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account
#1150024239917; and said account was issued to Defendant(s) by SEARS, the original creditor.
4. Defendant received, accepted and used the account to its benefit.
5. This account is in default and Defendant(s) has an unpaid balance of $3,540.34. A true and correct
copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A".
6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are
included in Exhibit "A".
7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as
above.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
• $3,540.34 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & ASS C TES, P.C.
Attorney ffin in ff
A Law Firm Engage Debt Collection
BY:
David J. A
Dated: 5/13/2008
Our File No.: 160168
VERIFICATION
David J. Apothaker, Esc. 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
subject to the penalties of 18 Pa.C.S.A. 4904 relating
understands that the statements therein are made
falsification to authorities.
David J. Apothaker
Attorney for Plaintiff
DATE: 5/13/2008
LVNV FUNDING LLC
c/o Apothaker & Associates, P.C.
2417 Welsh Road, Suite 21 #520
Philadelphia, PA 19114
BRAD WIEST
14 GRAY PL
MECHANICSBURG, PA 17055-5650
STATEMENT OF ACCOUNT
Debtor's Name: BRAD WIEST
Account Number: 1150024239917
Original Creditor: SEARS
Balance Due: $3,540.34
Our File No.: 160168
EXHIBIT "A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-03234 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LVNV FUNDING LLC
VS
WIEST BRAD
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WIEST BRAD the
DEFENDANT
, at 1343:00 HOURS, on the 31st day of May , 2008
at 807B FAIRFIELD STREET
MECHANICSBURG, PA 17055-5650
by handing to
BRAD WIEST
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 18.00
Service 18.00
Affidavit .00
Surcharge 10.00
4/04IDP 00
46.00
So Answers:
R. Thomas Kline
06/02/2008
APOTHAKE
Sworn and Subscibed to By:
before me this day
of A.D.
Our File No:: 160168
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.
BRAD WIEST
Defendant.
TO THE PROTHONOTARY:
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-3234
Civil Action
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter judgment against Defendant, BRAD WIEST, in the default of an Answer, in the amount of
$3,718.47 computed as follows:
Amount claimed in complaint: $3,540.34
Amount Paid: - $(0.00)
Interest from May 13, 2008 to 05/14/09
at the legal interest rate of 6.000 per annum $178.13
Costs $0.00
Attorney fees $0.00
TOTAL $3,718.47
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, BRAD WIEST, last know address is,1..4 GRAY PL MECHANICSBURG, PA 17055-5650.
APOTHAKER & S IATES, P.C.
Attorneys or P ' tiff
A Law Firm Ensa ed ' ebt Collectioi
By:
David J.
Dated: 5/14/2009
Our File No.: 160168
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.
BRAD WIEST
Defendant.
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-3234
Civil Action
AFFIDAVIT OF NON-MILITARY SERVICE
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 14 GRAY PL
MECHANICSBURG, PA 17055-5650.
We inquired with the web site of the Defense M wer Data Center, located at 1600 Wilson
Boulevard, Suite 400, Arlington, VA 22209-2593, if the of dant(s) is/are in any branch of the military.
Mary M. Snavely-Dixon, Director of the Defe e M power Da enter has sent back our inquiry
indicated that the Defendant(s) is/are not in the mili
David ,A!, er
Attorne or Plaintiff
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.
Depwkneut of Deknse Manpower Data Ceder MAY-14-2009 09.2330
Upon searching the inn daft backs afthe Department of Defense Manpower Data Cep, based an the xformatim dud
you mod, the above is the current of the ind1ividoid as to at branches of the Mikary.
nwq.kt
Mary M Snave?yr Dam Director
Deparkment of Defense - Manpower Data Center
1600 Wilson Bhd_, Suite 400
Arfi oon, VA 22209-2593
JU Dre#'ease Marf ower Data Center (DMDC) an organivifim of the Department c( Defense that Maintains the Defense
E rohned: and EIiBW Reporting System (DEERS) detabaw which is the o source of data on e1ioW for t ltary me"
care and other dty systems.
The Dqmtunts of Ddensestros#y suppoittsthe a darcem mt of the Services. Civic Relief Act [50 USCS Apps §§ 501
et seg], (SCRA) #bumady the Sow' and Safio& Cirri ReSdAct of IM) _ DMDC issued has hundreds ofdiousands of*does
not press any won indicating; the the individnal is cwr endy on active dnt3r" respon sm and has a gmimced a smal error
rate. In the event the ndivAW referenced above, or my laity iinendw, f iend, or rep vsentWve attests in any memner that the
imp is an active duty. or is owe entitled to The protections of the SCRA, you are saronoy encouraged to obtain further
veracadon, of the persoes active duty status by cow that persods wry Service via the "d tLmr URL provided
below. M you, have evidence the person is on active-duty and you fol to obtain this addWoaat Milawy Service venTratim
provisions of the SCRA may be invoked against you-
If y obtain firther infinniistion about the person ( e.g., an SSN. improved accuracy of DOB, a m dclfe name}, you can submit
your request again at this Web site and we wit provide a new certi a for that finery.
Ilm response reflects current active duty std only. For historical won, please contact the teary Service SCRA points-
of«codt.
See: bit JIvvww.
WAR3VB+ffir. This certficaw was provided based on a name and SocW Security number CSC? provided by the requester.
Providing an wonem same or SSN wB ramie an erroneous mete to be provided.
RWrrlDaBl VMA
teary Status Report
rsuant to the Services s Civil Relief` Act
160168 OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
LVNV FUNDING LLC )
VS. )
BRAD WIEST )
To: BRAD WIEST
14 GRAY PL
MECHANICSBURG, PA 17055-5650
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-3234
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
Date of Notice: July 01, 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
DA I J. APOTHAKER, ESQUIRE
APOT R & 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
'SHERIFF'S RETURN - REGULAR
CASE NO: 20.08-03234 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LVNV FUNDING LLC
UN 2008
lru J
VS WIEST BRAD
SHAWN HARRISON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
WIEST BRAD the
DEFENDANT at 1343:00 HOURS, on the 31st day of May 2008
at 807B FAIRFIELD STREET
MECHANICSBURG, PA 17055-5650 by handing to
BRAD WIEST
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 18.00
Service 28.00
Affidavit .00
Surcharge 10.00
.00
46.00
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
06/02/20
APOTHAKE
By:
A.D.
f
Cat t (v _.
2009 FI `" N f
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CiY V
Pb Al?rq
41 -S
t ,
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: BRAD WIEST
14 GRAY PL
MECHANICSBURG, PA 17055-5650
LVNV FUNDING LLC
Plaintiff,
VS.
BRAD WIEST
Defendant.
} COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 08-3234
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, Esq. at this telephone number: 215-634-8920
5/,2%9
Our File No.: 160168
LVNV FUNDING LLC
Plaintiff
vs.
BRAD WIEST
Defendan
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
goo/
1ac,6,i d s4.
NO.: 08-3234
s)
Pce
Rf;\ 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 BRAD WIEST, defendant(s); and
(3) against MEMBERS 1ST FCU 1711 SPRING RD CARLISLE, PA 17013, Garnishee
(4) and index this writ in the judgment index
(a) against BRAD WIEST, defendant(s), and
(b) against MEMBERS 1ST FCU 1711 SPRING RD 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
Interest from May 20, 2009
Minus Payments made
Plus Costs
Total
4a:ct .00 -vaOJ
L16,0u
006 "
$3718.47
$912.54
-$
$179.00
$4810.01
David J. Apothaker, Esquire
Attorney for Plaintiff(s)
c.
oat. so LC-
oao
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. NO 08-3234 Civil Term
CIVIL ACTION — LAW
BRAD WIEST
WRIT OF EXECUTION
(Pa R.C.P. 3252)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against BRAD WIEST, 809 FAIRFIELD STREET, APT A,
MECHANICSBURG, PA 17055 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, 1711 SPRING ROAD, CARLISLE, PA 17013- ALL
ASSETS AND ACCOUNTS, INCLUDING, BUT NOT LIMITED TO, BANK ACCOUNTS, BROKERAGE
FROM 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
1
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.
(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 $3,718.47 Plaintiff Paid
Interest FROM MAY 20, 2009 - $912.54 Law Library $.50
Attorney's Comm. % Due Prothonotary $2.25
Attorney Paid $167.50 Other Costs $179.00
Date: 09/11/14 2Q.fLLJLiT.104,4/L
David D. Buell, Prothonotary
(Seal)
2€4d
Deputy
REQUESTING PARTY:
Name : DAVID J. APOTHAKER, ESQUIRE
Address: APOTHAKER SCIAN P.C.
520 FELLOWSHIP ROAD C306
P.O. BOX 5496
MT. LAUREL, NJ 08054
Attorney for: PLAINTIFF
Telephone: 856-780-1000
Supreme Court ID No.
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
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
1HE PROTHOHOT,',i
?fliii SEP 24 All 10: 07
CUMBERLAND COUNTY
PENNSYLVANIA
Ronny R Anderson
Sheriff 1, cieititorti
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor OFFICE OF THE SHER1FP
LVNV Funding LLC
vs.
Brad West
Case Number
2008-3234
SHERIFF'S RETURN OF SERVICE
09/22/2014 11:25 AM - 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 Laurie Shultz, Member Services,
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 September 2 4 to Brad West at 809
Fairfield Street, Apartment A, Mechanicsburg, PA 17055.
September 23, 2014
CountySuite Sheriff, Toloosoft, inc.
WILLIAM CLINE, DEPUTY
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
Our File No.: 160168
)
LVNV FUNDING LLC )
)
Plaintiff )
vs. )
)
BRAD WIEST ) NO.: 08-3234
809 FAIRFIELD ST APT A )
MECHANICSBURG, PA 17055 )
XXX -XX -3922 )
)
Defendant )
)
MEMBERS 1ST FCU )
)
Garnishee )
11.34CAEP ERAS "-TO'
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Civil Action
RECEIVED
SEP 2 4 2014
CD r
-"0
CZ, C/3
ni
INTERROGATORIES TO GARNISHEE
TO: MEMBERS 1ST FCU, Garnishee:
You are required to file answers to the following Interrogatories within twenty (20) daysftelr sg-vic.iipon 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?
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)?
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?
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?
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?
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? \AC)
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.
, oc
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.
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.
Dated: —711q 1'(
David J. Apothaker, Esquire
APOTHAKER SCIAN P.C.
520 Fellowship Road C306
PO Box 5496
Mount Laurel, New Jersey 08054
(856) 780-1000
Attorneys for Plaintiff
RECEIVED
SEP 2 4 2014
11/05/2014 WED 1148 FAX 856 780 1020 4-4-4 mernbera first 0002/003
Our File No.: 160168
LVNV FUNDING TIC
VS.
Plaintiff
BRAD WTEST
300 COMMERCE DRV ROOM 313
NEW C(JMBERLAND, PA 17070
Please contact our office if you need the
Social Security number again.
Defendant
MEMBERS IST FCU
Garnishee
RECEIVED
NOV 0 5 2014
)
)
) COURT OF COMMON PLEAS 01'
) CUMBERLAND COT JNTY
)
)
) NO.: 08-3234
)
) Civil Action -,rri cp
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SUPPLEMENTAL INTERROGATORIES TO GARNISHEE
'FO: MEMBERS 1ST KU, 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 defcndant(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 dcfcndant(s) any money or were liable to defendant(s)
lOr any reason? k 01V
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 delendant(s)?
3 1°
At the time you were served or any.1)
su sequent time did you hold legal title to any property
of any nature owed solely or in part by the delendant(s) or in which the defendant held or
claimed any interest? t4.s.yi)
4. At the time you were served or at any subsequent time did you hold as fiduciary any property
in which the delendant(s) had any interest?
11/05/2014 WED 11:49 FAX 856 780 1020 --- members first 2003/003
•
RECEIVED
.. NOV 05.2014
5. At any time before or alter you were served did the defendant(s) transfer or deliver any
property to you or to any person or place purse .ant to your direction or consent and what was
the consideration thereof? •
6. At any time after you were served did you pay, transfer or deliver any moncy or property to
the def'endant(s) or to any person or place pursuant to the def'endant's direction or otherwise
discharge any claim of the defendants) against you?
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 arc deposited
electronically on a recurring basis and which are identified as being funds that upon deposit
arc exempt from execution, levy or attachment under Pennsylvania or Federal law? If so,
identify each account and stale 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 defendants) 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.
• e, -3.3,59 -Lob c chi n 5 f3370-
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.
Dated: 1,1
David J. A er, Esquire
APOTHAKER SCTAN P.C.
520 Fellowship Road C306
PO Box 5496
Mount Laurel, New Jersey 08054
(856) 780-1000
Attorneys for Plaintiff
44,
Our File No.: 160168
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
Plaintiff
vs.
BRAD WIEST
NO.: 08-3234
Defendant
MEMBERS 1ST FCU
Garnishee
PRAECIPE TO ENTER JUDGMENT AGAINST THE GARNISHEE
TO THE PROTHONOTARY:
Enter judgment against the garnishee:
MEMBERS 1ST FCU
for the following pro.erty of the defendant admitted in his answers to interrogatories to be in
said garnishee's po' ess.•n in the amount of:
$537.86
David J. Apothaker, Esquire
APOTHAKER SCIAN P.C.
CK� //91.1.1
4:k 341,1987..
MA la, fial
f y'
Our File No.: 160168
TO: MEMBERS 1ST FCU
1711 SPRING RD
CARLISLE, PA 17013
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
Plaintiff
vs.
BRAD WIEST
NO.: 08-3234
Defendant
MEMBERS 1ST FCU
Garnishee
NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER
HAS BEEN ENTERED AGAINST YOU.
(TYPE PROTHY NAME HERE)
PROTHONOTARY 1/4-7-0,/
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CONTACT:
David J. Apothaker, Esquire
Attorney for Plaintiff
520 Fellowship Road C306
PO BOX 5496
Mount Laurel, NJ 08054
800-672-0215