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HomeMy WebLinkAbout09-2367• Our File No.: 196636 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. R MICHAEL LONG 46 GARDEN PKWY CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (A-a3(n'l 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 •Ou* File No.: 196636 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. R MICHAEL LONG 46 GARDEN PKWY CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 R MICHAEL LONG, an adult individual residing at 46 GARDEN PKWY CARLISLE, PA 17013. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5121075036175623; 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 $4,707.63. 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 $4,707.63 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOC , P.C. Attorney for Pl ' ff A Law Firm Engaged in ebt Vflectioi BY: David J. Apoffi+er, Esquire Dated: 4/8/2009 Our File No.: 196636 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 de igned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat' to worn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 4/8/2009 Current Owner: LVNV Funding LLC Original Creditor: Sears\ SEARS GOLD MASTERCARD Previous Owner: Citibank Statement Closing Date: 12/24/2008 12:00:00 AM LVNV Purchase Date: 09/26/2007 Account Origination Date: 09/25/2004 Accountnumbee, 5121075036175623 Owing Collected Balance R Long Principal $ 4,565.05 $ - $ 4,565.05 ***-**-8713 Interest $ - $ - $ - 46 GARDEN PKWY Atty Fee $ - $ - $ - CARLISLE, PA 17013 Misc Cost $ - $ - $ - New Balance $ 4,565.05 $ - $ 4,565.05 TRANSACTIONS Transaction Date Description Amount 10/08/2008 Pavment NSF $ (3.368.41) This statement is not an original. This statement has been generated on behalf of LVNV Funding LLC, account owner. cs? ,.. OF Tf P ` GARY 2009 15 AN 114 0 50 Pct Arty e?# taWgc?? ?? aa3?5a Sheriffs Office of Cumberland County R Thomas Kline ,qtr at Climb, Edward L Schorpp Sheriff 4# Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE CF THE SrERJFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/20/2009 07:55 PM - Timothy Black, Deputy Sheriff, who being duly swom according to law, states that on April 20, 2009 at 1955 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: R. Michael Long, by making known unto Jessie Long, wife of defendant, at 46 garden Parkway, Carlisle, Cumberland County, Pennsylvania, 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 April 21, 2009 SO ANSWERS, - -11 R THOMAS KLINE, SHERIFF Thep y eriff Docket NO. 2009-2367 LVNV Funding v R. Michael Long FILED- 0i"FICE :w "" ?Y 2009 APR 27 AM II; 25 r us e: i v 1 Defendant. Our file No.: 196636 - d? APOTHAKER & ASSOCIATES, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 38423 LVNV FUNDING, LLC Plaintiff, VS. R MICHAEL LONG COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-2367 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on April 24, 2009, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, R MICHAEL LONG parties as follows: 1. Defendant agrees to pay the sum of $4,898.14, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $4,898.14 shall be paid by the by Defendant, R MICHAEL LONG, to the attorneys for Plaintiff in the following manner: a. $734.00 to be paid on or before April 24, 2009; b. $100.00 to be paid bi-weekly, beginning May>6,'2009 until paid in full. 1 All checks are to made payable to LVNV FUNDING, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 #r Il - Our file No.: 196636 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $4,898.14, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to R MICHAEL LONG by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plai iff A Law Firm En2ap-ed in t Collection By: F Sian, Esquire R MICHAEL LONG r72009 MAY 1 5 PN 2.2 3 ff u?, Our File N6.: 196636 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 vs. Plaintiff R MICHAEL LONG Defendant FILED-OFFICE i.; 1 HE PROTHONOTARY 2011 KA R ! 1 PH 1: t 6 U PENNSYLVAN q TY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2367 Civil Action PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, LVNV FUNDING, LLC, and against Defendant, R MICHAEL LONG, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on May 15, 2009, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of- Current Balance: Less: Payments: Plus: Interest from May 15, 2009 TOTAL $ 4,835.14 ( 1,634.00) 0.00 $ 3,201.14 David J. Apothaker, Esq. Attorney for Plaintiff Dated: March 5, 2011 Q16 Q?n?? t ly• ob ? -W ?A ?A? V4 asl0 y-7 v00-4ce. jma;le d Our File No.: 196636 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. R MICHAEL LONG NO.: 09-2367 Defendant David J. Apothaker, Esquire, certifies as follows: Civil Action 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on May 15, 2009, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of $4,835.14, giving the Defendant credit for payments made totaling $1,634.00, for a total of $3,201.14. I verify that the statements made in this Certifica pn are true and correct. I understand that false statements herein are made subject to the p a ies of 18 Pa.C S A. W04, relating to unsworn falsification to authorities. // David J. pothaker, Esq. Attorney r Plaintiff Dated: March 5, 2011 Our File No.: 196636 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. R MICHAEL LONG Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2367 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 46 GARDEN PKWY CARLISLE, PA 17013. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209,253, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the De ns Manp er Data Center has sent back our inquiry indicated that the Defendant(s) is/are not ?p tl* mil' ary. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Mar-05-2011 06:53:55 < Last Name First/Middle Begin Date Active Duty Status Active Duty End' Date Service Agency LONG ROBERT Based on the information you have furnished, the DMDC does not possess any MICHAEL information indicating the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Ott 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 DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 el seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL https/lwww.defenselink.mil/fan/"pas/PC09SLDR.htmi. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the https://www.dmde.osd.miUappj/scra/popreport.do[3/5/2011 9:51:15 AM] Request for Military Status President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date' on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:9D9TAKSE0L https://www.dmdc.osd.mil/appj/scra/popreport.do[3/5/2011 9:51:15 AM] Our file No.: 196636 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 38423 LVNV FUNDING, LLC Plaintiff, VS. R MICHAEL LONG Defendant. f COURT OF COMMON PLEAS } CUMBERLAND COUNTY } DOCKET NO.: 09-2367 Civil Action `- -m- } STIPULATION IN LIEU OF JUDGMENT } } The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on April 24, 2009, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, R MICHAEL LONG parties as follows: 1. Defendant agrees to pay the sum of $4,898.14, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $4,898.14 shall be paid by the by Defendant, R MICHAEL LONG, to the attorneys for Plaintiff in the following manner: a. $734.00 to be paid on or before April 24, 2009; b. $100.00 to be paid bi-weekly, beginning May,P. ,'2009 until paid in full. 7 All checks are to made payable to LVNV FUNDING, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 196636 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $4,898.14, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to R MICHAEL LONG by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plain iff A Law Firm Engaged in t Collection By: F.'-Sc'ian, Esquire R MICHAEL LONG Our File No.: 196636 LVNV FUNDING, LLC Plaintiff vs. R MICHAEL LONG Defendant(s) QtvAul ibYtiotti IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-2367 b_v vs\t pr 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 R MICHAEL LONG, defendant(s); and (3) against BELCO COMMUNITY CREDIT UNION 17050, Garnishee(s); (4) and index this writ in the judgment index 5304 CARLISLE PIKE MECHAM9BIFG4!:. (a) against R MICHAEL LONG, defendant(s), and (b) against BELCO COMMUNITY CREDIT UNION 5304 CARLISLE PIKE MECHANICSBURG, PA 17050, 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 $3201.14 Interest from March 11,2011 $497.02 04 Minus Payments made -$800.00 — Plus Costs Total $193.00 $3091.16 David J. Apothaker, Esquire s9 .9s pea- Attorney for Plaintiff(s) 6. Sou. cb_ 1424. 0 aa 0-1S6xJ-55,e, 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 09-2367 Civil Term CIVIL ACTION — LAW R. MICHAEL LONG WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against R. MICHAEL LONG, 46 GARDEN PARKWAY, CARLISLE, PA 17013 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 BELCO COMMUNITY CREDIT UNIONGARNISHEE(S), as garnishee, 5304 CARLISLE PIKE, MECHANICSBURG, PA 17050- 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 $2,401.14 Plaintiff Paid Interest FROM MARCH 11, 2011 - $497.02 Law Library $.50 Attorney's Conun. % Due Prothonotary $2.25 Attorney Paid $158.50 Other Costs $193.00 Date: 09/11/14 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. . -.1wee_csb 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 OFC Z: QF Th LLJU. THE PROT HONO ?Th SEP 214 AM 10: 07 CUMBERLAND COUNTY PENNSYLVANIA LVNV Funding LLC vs. R Michael Long Case Number 2009-2367 SHERIFF'S RETURN OF SERVICE 09/22/2014 01:05 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, Belco Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Leta Phillips, Member Service, 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 23, o R. Michael Long at 46 Garden Parkway, Carlisle, PA 17013. September 23, 2014 (c) CountySuite Sheriff, Toleosoft, Inc. LA CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Our File No.: 196636 APOTHAKER SCIAN P.C. By: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC Plaintiff vs. R MICHAEL LONG Defendant BELCO COMMUNITY CREDIT UNION Garnishee iLED-01: OF THE PRO TtIONCTI. 2014 OCT -3 PH CUMBERLN,i0 C,'?f,T COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-2367 Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, BEIIICO •OMMUNITY CREDIT UNION, dissolved. Kimberly F. S4Vian, Esquire Attorney for Plaintiff ami-q,5�d4 Clc,14- )1 tiqq (RI Our File No.: 196636 Apothaker Scian P.C. By: Derek A. Moatz, Esquire Attorney I.D. #205200 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC vs. R MICHAEL LONG Plaintiff, Defendant. THE V !LEU -OF ICE Cr E PROTHONOTAR, 20I4 OCT 20 PM t: 06 CUMBERLAND COUNTY PENNSYLVANIA ) COURT OF COMMON PLEAS ) CUMBERLAND COUNTY ) ) ) ) NO. 09-2367 ) ) ) PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. Apothaker Scian P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: Derek A. Moatz, Esquire II 111 * Q 1 191111111,11111All 111 q.6o P6 A-rni op -115(148 fl31 aL/85