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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" J 00 r c"a ? ? (? ,?? DTI Co < 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 rr 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 (0 CD z•-• cp -r CDF:: e —4 (-il —3 —; r"--) — r CO .77tr- 17:76 — AAS -10 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