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HomeMy WebLinkAbout08-5604Our File No.: 173660 APOTHAKER & ASSOCIATES, P.C. 13Y: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JEFFREY P TRAYER 69 CHERRY LN CARLISLE, PA 17015-7805 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. OS - SI.Oy a U I `7? 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. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 173660 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JEFFREY P TRAYER 69 CHERRY LN CARLISLE, PA 17015-7805 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O r-5"L D y C?c ?? CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JEFFREY P TRAYER, an adult individual residing at 69 CHERRY LN CARLISLE, PA 17015-7805. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #4888934999044471; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $5,663.07. 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 $5,663.07 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS IATES, P.C. Attorney fo P ' tiff A Law Firm Enizaiz Debt Co iol BY: Dated: 9/10/2008 David J. A Esquire Our File No.: 173660 VERIFICATION David J. Apothaker. Esquire 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 un rsi ed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating o worn falsification to authorities. David J. Apothaker, ire Attorney for Plaintiff DATE: 9/10/2008 JEFFREY P TRAYER 69 CHERRY LN CARLISLE, PA 17015-7805 STATEMENT OF ACCOUNT LVNV FUNDING, LLC Debtor's Name: JEFFREY P TRAYER Account Number: 4888934999044471 Original Creditor: BANK OF AMERICA Balance Due: $5,663.07 Our File No.: 173660 EXHIBIT "A" n "4. ?' o d " F ? y C r.3 C= ?? CZz 00 va SHERIFF'S RETURN - REGULAR CASE NO: 2008-05604 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS TRAYER JEFFREY P WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TRAYER JEFFREY P the DEFENDANT at 69 CHERRY LN at 1933:00 HOURS, on the 26th day of September, 2008 CARLISLE, PA 17015-7805 JEFFREY P TRAYER 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 18.00 Service 6.00 Affidavit .00 Surcharge 10.00 00 1 01 vi/o 34.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 10/01/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff A. D. ..4 Our File No.: 173660 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. JEFFREY P TRAYER Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5604 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, JEFFREY P TRAYER, in the default of an Answer, in the amount of $5,791.57 computed as follows: Amount claimed in complaint: $5,663.07 Amount Paid: - $(0.00) Interest from September 10, 2008 to 03/14/09 at the legal interest rate of 6.000 per annum $128.50 Costs $0.00 Attorney fees $0.00 TOTAL $5,791.57 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 that Plaintiff s address as LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C 306, Mount Laurel, NJ 08054 and that Defendant, JEFFREY P TRAYER, last know address is 69 CHERRY LN CARLISLE, PA 17015-7805. APOTHAKER & Attorney A Law Firm En g By: David J. RTES, P.C. Debt Collection Dated: 3/14/2009 t ? TO: JEFFREY P TRAYER 69 CHERRY LN CARLISLE, PA 17015-7805 LVNV FUNDING, LLC Plaintiff, VS. JEFFREY P TRAYER Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5604 Civil Action 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 A Our File No.: 17360 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. JEFFREY P TRAYER Defendant. Civil Action AFFIDAVIT OF NON-NULITARY 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 69 CHERRY LN CARLISLE, PA 17015-7805. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the, Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5604 David J. Apothaker Attorney for Plaintiff Data Center, located at 1600 Wilson ) is/are in any branch of the military. Data Center has sent back our inquiry 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. • "" 173660 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JEFFREY P TRAYER ) NO. 08-5604 To: JEFFREY P TRAYER 69 CHERRY IN CARLISLE, PA 17015-7805 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: November 10, 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 1? DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAR-14-2009 06:51:35 < Last Name First/Middle Begin Date Active Duty Status Service/Agency TRAYER JEFFREY P 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. Al t, 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: http://www.defenselink.miUfaq/pis/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: FPQWUCTUAM https://www.dmde.osd.mil/scra/owa/scra.prc_Select 3/14/2009 CASE N0: 26o8-05604 P SHERIFF'S RETURN - REGULAR COMM014WEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS j I i TRAYER JEFFREY P WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon TRAYER JEFFREY P DEFENDANT the at 1933:00 HOURS, on the 26th day of September, 2008 at 69 CHERRY LN CARLISLE, PA 17015-7805 by handing to JEFFREY P TRAYER 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 6.00 Affidavit .00 Surcharge 10.00 .00 34.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 10/01/2008 APOTHAKER & ASSOCIATES By. v ! Deputy Sheriff of A.D. I " 3 N ,O r ^' Y t C-7 t` -TI ?.aqq7 ? 1 2182164 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 r.. r 'i.10,111 IVY CUNBERL P NI'S } ��D ©Ut TY Po TP LVNV FUNDING LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. Jeffrey P Trayer DOCKET NO. : 08-5604 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above -captioned matter. GORDON & WEINBERG, P.C. BY: P012 FREDERIC IEINBERG, ESQUIRE JOEL M. INK, ESQUIRE Attorne�v for Plaintiff CERTIFICATION OF SERVICE I, JOEL M. FLINK, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre -paid, to all other parties or their counsel of record. Dated: 1; / r�- JOEL M. FLI rigS`QUI 2182164 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 IW T,-jr 2014 JUN 1 9 PP1 3: 5 .111 B RL AND COUNTY PENNSYLVANIA LVNV FUNDING LLC 55 BEATTIE PLACE GREENVILLE 29601 vs. Jeffrey P Trayer =69 CHERRY LN CARLISLE PA 17015 and Members 1st FCU =401 East King St Shippensburg, PA 17257 GARNISHEE TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-5604 PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against Jeffrey P Trayer (2) against Members 1st FCU defendant(s)and garnishee(s) (3) Amount Due Interest from March 24, 2009 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL -oma 1 SS. SO Pcbtkv 19‘lt,t, FREDERIC I. RG, ESQUIRE at_iwil4564 JOEL M. FLIN ESQUIRE $5,791.57 $1,809.72 $.00 Attorney for V-4-- 36-7 ss Plaintiff Uorii-DtS--13`ssA 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. JEFFREY P. TRAYER WRIT OF EXECUTION (Pa R.C.P. 3252) NO 08-5604 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against JEFFREY P. TRAYER, 69 CHERRY LANE, CARLISLE, PA 17015 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, 401 EAST KING STREET, SHIPPENSBURG, PA 17257 (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. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 . 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 $5,791.57 Interest FROM MARCH 24, 2009 - $1,809.72 Attorney's Comm. % Attorney Paid $155.50 Date: 6/19/14 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 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 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY L iJ-U F l THE ()ROTHONOTL F Os' of Cntribrr, OFFICE OF THE SHERIFF 2314JUN 30 AM10:50 CUMBERLAND COUNTY PENNSYLVANIA LVNV Funding LLC vs. Jeffrey Trayer Case Number 2008-5604 SHERIFF'S RETURN OF SERVICE 06/26/2014 09:32 AM - Christopher Sharpe, 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, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Nicole Martin, Assistant Branch Manager, 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 June 27, 2014 to Jeffrey P. Trayer at 69 Cherry Lane, Carlisle, PA 17015. 7/ H IST C OP SO ANSWERS, S ARPE, DEPUTY June 27, 2014 RNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Toleosoft. inc. GvRDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV FUNDING LLC 55 BEATTIE PLACE GREENVILLE 29601 vs. Jeffrey P Trayer 69 CHERRY LN CARLISLE PA 17015 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEE COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-5604 -44su.5e, Lb INTERROGATORIES IN ATTACHMENT p1cz >✓ EZ -r. rn :*1- (— -Cr 3 .‹ '3 - = c.5'u" —; N) --< CO 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 my 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 the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? Ly,qn _ 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. ti 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which 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 an 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 if so what was the consideration therefore? N( cs„- 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 his(her, their) direction or otherwise discharge any claim of the defendant(s) against you N)// DATED: 7. 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 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, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 8.506, cd Sfzu.54- or‘k) t)-1 01) 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 the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.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)? FREDERIC I. WE'tNBEE1 , ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 2182164 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2014 JUL 21 P11 4:17 CU NBER�A1VD PENNSYLVANIA }' LVNV FUNDING LLC vs. Jeffrey P Trayer and Members 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 08-5604 PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against Members 1st FCU, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: P011 FREDERIC I. WE G, ESQUIRE JOEL M. FLINK, SQUIRE Attorney for Plaintiff cokA sc.sogioL et_kci")1GtD