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HomeMy WebLinkAbout09-5441 LVNV FUNDING LLC LOWE'S CONSUMER c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 Plaintiff Vs. John O Workman 3 MICHAUX DRIVE NEWVILLE PA 17241 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: 09 -SWI 6 ULLc-? PRAECIPE FOR ENTRY OF JUDGMENT Defendant To the Prothonotary of CUMBERLAND County: 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: April 21, 2009 B) Amount of Judgment: $5,793.11 C) Interest From: April 21, 2009 2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3) I hereby certify that the address of the plaintiff is: LVNV FUNDING LLC LOWE'S CONSUMER c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 4) I hereby certify that the address of the defendant is: John 0 Workman 3 MICHAUX DRIVE NEWVILLE PA 17241 Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 1729 Pittston Ave, Scranton, PA 18505 570-558-5510 Ext. 101 Attorney ID 86285 LVNV FUNDING LLC LOWE'S CONSUMER In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff : NO: vs. John O Workman 3 MICHAUX DRIVE NEWVILLE PA 17241 NOTICE OF FILING JUDGMENT Defendant : Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the amount of $.5''Y Q 3. 1( on le 1,19,169 By: /r/ ?Yr 0/- ? If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 1729 Pittston Avenue Scranton, PA 18505 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) LVNV FUNDING LLC LOWE'S CONSUMER c/o Edwin A. Abrahamsen & Assoc. 1729 Pittston Avenue Scranton, PA 18505 Plaintiff vs. John O Workman 3 MICHAUX DRIVE NEWVILLE PA 17241 Defendant . In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): John O Workman is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): John O Workman is(are) older than eighteen years of age; That the employment status of the defendant(s): John 0 Workman is(are) unknown. Request for Military Status Department of Defense Manpower Data Center Adak& IF Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 JUN-16-2009 06:07:25 -. Last Name First/Middle Begin Date Active Duty Status Service/Agency WORKMAN JOHN O 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. )6t 14. 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.mil/faci/pis/PC09SLDR.htm] 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:PLLLXFEXTA https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/16/2009 'COMMONWEALTH OF PENNSYLVANIA rr)i iNTY nF• CMMERLAIND Mag. Dist. No.: 09-3-02 NOTICE OF JUDGMENT/TRANSCRIPT CIVIL CASE PLAINTIFF: NAME and ADDRESS r 7 LVEV FUNDING LLC 1729 PITTSTON AVE C/O EDNX N A ABRAHAMEIN LSCRAZTON, PA 18505 J VS. DEFENDANT: NAME and ADDRESS rMOIIIMLAIN JOHN O ? , 3 ILICRAUX DRIVE INXWILLE, PA 17241 L J Docket No.: CV-0000027-09 Date Filed: 3/20/09 MDJ Name: Hon. VIVIAIN COHICK Address: 55 PENN DR EEMVILLE, PA Telephone: (717 ) 776-3187 17241 LV]NV FUNDING LLC 1729 PITTSTOIN AVE C/O EDNX N A ABRAHAILSEIN SCRANTON, PA 18505 THIS IS TO NOTIFY YOU THAT: Judgment: DEFAULT JUD(IEEIIT PLTF (Date of Judgment) 4/21/09 0 Judgment was entered for: (Name) LVINV FUMING LLC © Judgment was entered against: (Name) WORMIAD• JO>ON O in the amount of $ 5, 793.1 Defendants are jointly and severally liable. ? Damages will be assessed on Date & Time 1-1 This case dismissed without prejudice. Amount of Judgment Subject to Attachment/42 Pa.C.S. § 8127 ? Portion of Judgment for physical damages arising out of residential lease $ Amount of Judgment $ 5,668.61 Judgment Costs $ 124.50 Interest on Judgment $ .00 Attorney Fees $ .00 Total $ 5,793.11 Post Judgment Credits $ Post Judgment Costs $ Certified Judgment Total $ ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. -at-o9 Date c , Magisterial District J I certify that this is a true and correct copy of thft record of the proceedings containing the judgment. 6,11,J07 Date , Magisterial District Judge My commission expires first Monday of January, 2012-a51Xj SEAL AOPC 315-07 1?0 DATE PRINTED: 4/21/09 11:10:00 AN Fli 1 ? . P7.2s CK-? ?rzz73 ? - .,Ag81( ? Nv4 rcc- •-nc,, L t (c r, WRIT F EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSY VANIA) NO 09-5441 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING LLC LOWE'S CONSUMER Plaintiff (s) From JOHN O. WORKMAN, Michaux Drive, Newville, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach he property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: M & T BANK, 28 WALNUT BOTTOM ROAD, SHIPPENSBURG, PA 17257-8219 - ANY AND ALL ACCOUNTS OF THE DEFEND NTS IN THE POSSESSION OF GARNISHEE INCLUDING BUT NOT LIMITED TO SAVINGS A COUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. and to notify the garnishee(s) that: ( paying any debt to or for the accour (s) or otherwise disposing thereof; (3) If property of the defendant(s) of anyone other than a named garni garnishee and is enjoined as above ; Amount Due $3,593.11 Interest $85.64 Atty's Comm % Atty Paid $54.25 Plaintiff Paid Date: 3/24/11 (S--al) REQbESTING PARTY: Name MICHAEL R. RATC Address: LAW OFFICE OF i an attachment has been issued; (b) the garnishee(s) is enjoined from of the defendant (s) and from delivering any property of the defendant levied upon an subject to attachment is found in the possession , you are directed to notify him/her that he/she has been added as a L.L. $.50 Due Prothy $2.00 Other Costs bAymb *1a, L L L David D uell, Prothon tart' By: Deputy ESQUIRE A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 1 Attorney for: PLAINTIFF Telephone: 570-558-5510 Supreme Court ID No. 86285 PRAECIPE FOR WRIT OF E LVNV FUNDING LLC LOWE'S VS. John O Workman 3 MICHAUX DRIVE NEWVILLE PA 17241 VS. M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a) Plaintiff Defendant Garnishee In the Court of Common Pleas of CUMBERLAND County, Pennsylvani a Civil Division M cn ?, r- NO: 09-5441 3> n z c) PRAECIPE FOR WRIT OF EXECUTION AN-I) ATTACHMENT (MONEY JUDGMENT) -zap ?o -v v ter`: To the Prothonotary: TO SATISFY THE DGMENT, ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMB RLAND County, Pennsylvania; (2) Against: John O Workman (3) And against: M&T BANK 28 W LNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 (4) and index this writ (a) against Defendant(s) (b) against Garnishee(s), as a lis pendens against the real property of he defendant(s) in the name of the Garnishee(s), any and all accounts of the defendant(s), in the possession of Garnish e, including but not limited to savings account balances; checking account balances; Certificates of Deposit; Money arket Accounts; contents of Safety Deposit Boxes. Defendant's SSN(s): 200-60-6546; (5) D Date: March 2, 2011 u4. SD V a in. 0 A s Car SO TCA CL IL . Judgment Interest Payments Clerks Fee Sheriff Poundage Total $5,793.11 $85.64 ?,ro""`\P $2,200.00 - M.ws. Qom'' ? . SD LL (:?j 7 aas7o43 Mlcfiael F. Ratchford, Esc Edwin A. Abrahamsen &, Attorney for Plaintiff mratchford@eaa-law.com .C. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Vaay;r ofn+?aurj'd OFt C iF i . SrcPIFF OF THELP OTNO OT,4RY 2011 APR -8 AM 9. 15 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor LVNV Funding LLC Lowe's Consumer I VS. John O Workman Case Number 2009-5441 SHERIFF'S RETURN OF SERVICE 04/01/2011 09:23 AM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on April 1, 2011 a 0921 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: John O. Workman, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing tc Donna Egolf, Teller, 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 April 7, 2011 to John O. Workman, at 3 Michaux Drive, Newville, PA 17241. SO ANSWERS,, April 07, 2011 RON R ANDERSON, SHERIFF Tim wic, Deputy (r) CountySutte Sherittf TP pas.0tt Inr. LVNV FUNDING LLC In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Plaintiff Civil Division vs. John O Workman NO: 09-5441 Defendant Praecipe to Satisfy the Judgment PRAECIPE TO SATISFY THE JUDGMENT To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Satisfy the Judgment. ' 'r cD ten `` =c C:)C—, Thank you, c r� Mich . Ratchfor C�s(� Edwin A. Abraham en& Associates, P.C. Lawyer ID # 8628 120 N:Keyser Av nue Scranton PA 185 4