Loading...
HomeMy WebLinkAbout10-1022Our File No.: 241639 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. JEROME CLARK 1871 DOUGLAS DR CARLISLE, PA 17013 Defendant. FlLED-{a,=-ICE GE THE P^r t -'ONO-T'ARY 1010 FEB -9 AM 9: 51 CUNT _.-' n ?n» M; COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 109A NOTICE ???< <?i-erns 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 (2) +9x.00 Pb Ar Y Ww I (6qqg7 kTt a3q q&8 Our Me No.: 241639 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. JEROME CLARK 1871 DOUGLAS DR CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q / 6?;i- cN,I -f'og'` 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 JEROME CLARK, an adult individual residing at 1871 DOUGLAS DR CARLISLE, PA 17013. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #2116041005978268; and said account was issued to Defendant(s) by HSBC BANK NEVADA N.A., 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 $1,483.31. 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 $1,483.31 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS CIATES, P.C. Attorney r P ntiff A Law Firm Eniza ed i Debt CoUi6dioi BY: David J. Apl`f ker, Esquire Dated: 2/2/2010 ?. Our File No.: 241639 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to,orn falsification to authorities. David J. Ap thaker, Esquire Attorney or Plaintiff DATE: 2/2/2010 LVNV FUNDING LLC JEROME CLARK 1871 DOUGLAS DR CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: JEROME CLARK Account Number: 2116041005978268 Original Creditor: HSBC BANK NEVADA N.A. Balance Due: $1,483.31 Our File No.: 241639 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~~~~~ti5, of ~aunt~r~,f~~~# 2~IQ FE3 22 P~~ s~ ~~ ~ Edward L Schorpp Solicitor -,~~ ~ - .. ~! ~°/_ -~ LVNV Funding, LLC vs. Jerome Clark Case Number 2010-1022 SHERIFF'S RETURN OF SERVICE 02/16/2010 04:18 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 16 2010 at 1618 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jerome Clark, by making known unto himself personally, at 1871 Douglas Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 February 17, 2010 SO ANSWERS, R N R ANDERSON, SHERIFF ~~ By i' `"'. Deput .Sheriff ~c. f T'e~~cs~~?t Inc- w ~l.~.Q"lJ+"i t4.iG Our File No.: 241639 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 JEROME CLARK Defendant ZOiO APR 19 ~H 11~ 33 "~, , :J tai: i~~~\`j.~..'v~'c.hvf~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JEROME CLARK, in the default of an Answer, in the amount of $1,494.05 computed as follows: Amount claimed in complaint: $ 1,483.31 Less: Amount Paid: ( 0.00) Plus: Interest from February 2, 2010 to March 26, 2010 at the legal interest rate of 6.00% per annum 10.74 Attorney fees 0.00 TOTAL $ 1,494.05 I certify that Defendant, JEROME CLARK, last own address is 1871 DOUGLAS DR CARLISLE, PA 17013. ,,%' David J. Apolhaker, Esq. Attorney for Plaintiff Dated: March 26, 2010 ~14.n0 PA ~a~'ry c~~` ~~~t45a ~~ a~o7o9 ~oJ-~eR. ~a~'«I OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JEROME CLARK 1871 DOUGLAS DR CARLISLE, PA 17013 Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM 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: 800-672-0215 ~~~R f rc, LVNV FUNDING LLC vs. Plaintiff JEROME CLARK Our File No.: 241639 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 JEROME CLARK Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. 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. Dated: March 26, 2010 David J. Apothaker, Esq. Attorney for Plaintiff Our File No.: 241639 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. JEROME CLARK Plaintiff Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM 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 1871 DOUGLAS DR 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 ~5~93, if the Defendant(s) is/are in any branch of the military. ~,/ Mary M. Snavely-Dixon, Director of the De our inquiry indicated that the Defendant(s) is/are not Data Center has sent back 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. Dt aE'Ds~tmst \3atrFa Data Centre ~~ to ds~ Sretiict ltferaLezs ~°it~ RriefAct him-?6-24I~ 4ii:~?~#k~ List Frryt~!tiiddk Begin ihte :Leis a Utet~ Sgten Actnre ©stY Ead 17ate Senitce ti~ase Xltercp CLA1tSC : J.~©~~ $asezi `~ ttte szfrmttatkast }rya~~ bat a firznsshed. DjtI3C dogs rx~t lx,srss arto atFc~rrn4,~>tt ,mdt~ the ~ecleral stalvs- __ __ C'pttn t6r eiata baalzs uf' ~e c~I3 4far~x~u zti Data Cz~et. based ~ - sic przs~' ~ aCnr^~ r r$ st~tas ~` its as to aM braes cF t}is Gt~pTtiz~d Smcas ~~5xtisy, 2~~}°, '~S Ca~as_ Air Eisner„ \ C3s1a'l, Ps~Fc Hr~ahts, a~ Cpast . »~.~ ,r,~-~. V _l2. Suety*-Dnccxi, TArectrx at'~e - 41,~rsr D~a C 1ts40 ~`s~p Bb. d . SuaP -RtJO ~~, t'A 2_3t`1~-7cg3 The IIek'errs+: Lnirer I">adtt Cetaea ~VAaC) ~ an ~? ~ ~ Drplstuxst ~'~ ~'hfer~e Earl. am! ° Rrpa~ag Systxm !~'~EI~&) sLstabssc ~,i~fi is the ~cia[ sesacr t~f d~a fla 1€ar may ~ec9ieat amd ads ~Z stir. °Ihe I~dl str~-9'~ sUpP #~ c~arccme~ ~ sip S~n~r ~3rrrs Cis•~ Rr1icFAct X50 [75C A~ ~ a (52 et s^t~, a~ {$CR.~;~ ~fitxrriech. kyyptan as t6r Shiers aow4 Sazlvrs' Ci+~ RthefAct crY 14ll~} D Las ensued huac6eds ~ "dc+es peKSea, any its ia~3catan~ tLaQ t~ inz3`icitLmt €s ct~trzui; sin a~ tk~;:' r . s, ~.9 has c~gesiertcei! ~ €zccar rate. Ia the c4~-,,c zbe aic~at rrfnmccci a1r~c.~e, ~r ~g fa; ss~u~ber. fii~u1, ~ r asseetsaa mr~mer tl~ tl;e a5i Lsal is caa antis r ~dy. ~ is pther,sisC entailed tct ~e paotectiw~s of :lee SCRA, pin az~e strcl} ~cc~aged to Ytbt fatrlher cnati~a ot'tLe• petum's st~us bt~ tlDau~rsz~z s S~nii~e pia dsc " trtil" L'RL btt~? ss a~defrnsefe~: mrl; seITE'rt~~_I Dr's.. ~f;~'ou . c ~id~rr t9tL prr6Sttt#5 4~tt -r dut•, ~f ti-oulast [~ abt~l~s add4ioaad Smicr ;'e~caAion. P~'t Prosssgaas. of ttx SCRrima? h~ imaakrd. a~ZSi yvu. 5rt =C t'SC ~.. ~531~c~- ';r t ou ~staia; , . ~ ~erscm {t;., an S4\, as~sm acc-t~racv of UC~B, a r~ }, gt~a sit -eca rrqutst aigatir at ills li'rb vte and wr tt71 ~xptu#e a.:.. rerttli~att £c*r tLffi: ?`:. This se+~,,e t ~tle _ r aciiti a dezt~ stars ' dam t~ ' a;ts fast Ott acts, a chug. ~'i# mar vc the prec 36 da}-s: Fca hsuxtca8 ' p6casr s»e~u~t tLe Service SL"ftA poems-,~f.ccmtact. ~faex ihferr~rutiox are ".~Ltativt,Aut~~S~rur"' Acinr six; stators as sepa~ts°d in this ceTriecaee is dnmstd in aceartlaoce 1 ~3 L; SC ~ ii}l id;~{ 1) for. a grtioel at'mxe than 3#1 ccnsrcutitix dais. Iso tree test ed' a mr~ba of ti:r \atianz6 Gtksd, 3 smue wader a caPx til actin a sas+ict a€uht,cizrd by dtc ~ e:zat of the , ~'~ fcx' s ~ ~ astxe tkaan 3A con~ttsm x cfa~s sun~~r ? _ L'4C § 5~~:if~ fist tsarpases of res}tondicy~ to a y deeFmred b~ th€ Frrs3dmt and Ss>ptcarrd b f Federal %bxis A~ ,saem~ C»tzvd Resersse {AUR i >,~ s cutist bt astiggrd t as atghcKi:ed an~b>li<atic~ position m the Emit the. sv}s~toti_ Thia ine4edts Naafi TARS. _'4~asin~ Caps Af:x ;nzsi Ctrast Ctnard RPAs A;-cr. e $~. szatva al~.~ ins tc~ a t;~atmed Srr~ic~p zt:rrr~xt ubc is ails acen~e dt resetssiu~d otFatsr pt'`dse CT.S Fk$?lic Hea&&h ~enrc ~x iLe \au.,aal C?ceat~c saki: ArmtsysFttcc~ .~dsszirsistrat ((:'St.IA€t: C~aanssiooed Ccugs~ for aprrxxl atmore thaw ?~~ coasct~r dacs. Cer~cr~e L'teder this SC,is'.9 it $++omder in .~'orets Cssds Ca~aaagc mda tLr SGR 4 is hraazkY ~ same comes and ides s~ ea~garus of petspns pn ttcEiue ~} far psagoses aEtlsr SClL4 sc~lta ~ oax tse ~ as uu ~tt~e~ 1?aty taxer this cett~ca~e. Iany rases arc$ss are to rtu~d tLc peciorl ofxtir~ dray. x~tiec6 caoa#d e:texul S(~RA protectic3mis- Pennants seeloag rp rt¢w ap websitc K slst>iid rhee3c to make store tfie prdrr5 tsn wluth S CRA ~ateetians art based halide oustlsrra extt the is~tsit~ dates at'ser~ce. Fttzz3ssrst~e, zaa~ pr a#`dsc 5i"Ft.?~ tnay aetepd w pss$ans vc~ ha4x rs+csier,i arde=s sv regsoat bar acts^s tibtg au to be ia~rrd but eehO base apt actually begun actis•r dzay or Y rrTsrntedf~ as..iht Last Date exe Actin lA>ry erary ~. ~ betatr5~ a. martbr:t raI'gral?ecti~ns aC SCRA ezte~ bt}-aad iLt dates afae~e chrr~ Thant who ttoatd rtFy am tlss eertiftcate ore wed #p stele gesals'sed legal camesel tp erwar that at ruts gaieazae~tcl to Srn~r s dse SCAR att• prc?tt~ird- SL'AR\~?G; Tbes cati6catr n~as Fxa+i&d based ere a aaau sad SS'd prosi~d Esy dst rrt~ster_ Prp.icfag see eaaruass name a< 55K ~ti~ rsxzst an eerti&ate to bt pr^aed. 241639 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JEROME CLARK ) NO. 10-1022 CIVIL TERM To: JEROME CLARK 1871 DOUGLAS DR CARLISLE, PA 17013 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: March 11, 2010 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 %/ 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 Our File No.: 241639 LVNV FUNDING LLC Plaintiff vs. - JEROME CLARK - Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -NO.: 10-1022 CIVIL TERM 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 JEROME CLARK, defendant(s); and (3) against MEMBERS 1ST FCU 1711 SPRING ROAD CARLISLE, PA 17013 and 320 N HANOVER ST CARLISLE, PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against JEROME CLARK, defendant(s), and __ tw y CT - c - CORNERSTONE FCU (b) against MEMBERS 1ST FCU 1711 SPRING ROAD CARLISLE, PA 17013 and CORNERSTONE FCU 320 N HANOVER ST 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 April 19, 2010 Minus Payments made Plus Costs Total Okt *P.ekYd a (s.t-(01et U N. boo & S'D $1494.05 $297.85 -$ $243.00 $2034.90 David J. Apothaker, Esquire Attorney for Pl intiff(s) s a. as -Dye (1. Sb LL.-- OL -1/- 163glo) 124/3t-104° d 616e P‘5-ej 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. JEROME CLARK WRIT OF EXECUTION (Pa R.C.P. 3252) NO 10-1022 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against JEROME CLARK, 701 STANWIX CIRCLE, APT. 3, 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 MEMBERS 1ST FCU, 1711 SPRING ROAD, CARLISLE, PA 17013 CORNERSTONE FCU, 320 NORTH HANOVER STREET, CARLISLE, PA 17013 GARNISHEE(S), as garnishee, 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. (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 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 $1,494.05 Plaintiff Paid Interest FROM APRIL 19, 2010 - $297.85 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs $243.00 Attorney Paid $180.15 Date: 6/09/14 (Seat/ REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD, C306 P.O. BOX 5496 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson �_l;re.; Sheriff Jody S Smith Chief Deputy Kilti JUN 17 All I f: (' 1 Richard, W Stewart Solicitor oFFiceOFTHE SHERIFF CUMBERLAND COUNTY PENNSYLVANIA dli'4�lP817✓r1t,�{��� THE i RO ! HO1yO {Ai 4f LVNV Funding, LLC vs. Jerome Clark Case Number 2010-1022 SHERIFF'S RETURN OF SERVICE 06/16/2014 10:40 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 Nicole Martin, 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. L OI✓fNE, DEPUTY SO ANSWERS, June 17, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriffs, Teleosoft. Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �p,<<��r of Enirabrr�vF10 CF THE PROTi�O1 O orifi 2014 JUN 17 AM 9: 48 CUMBERLAND COUNTY lceo THE w s :s' PENNSYLVANIA LVNV Funding, LLC vs. Jerome Clark Case Number 2010-1022 SHERIFF'S RETURN OF SERVICE 06/16/2014 10:45 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, Cornerstone Federal Credit Union, 5 Eastgate Drive, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Bahira Omerovic, 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 June 17, 2014 to Jerome Clark at 701 Stanwix Circle, Apartment 3, Carlisle, PA 17013. June 17, 2014 (c) CountySuito Sheriff, Teleosofi, Inc. ILLIAM CLINE, DEPUTY SO ANSWERS, RONR ANDERSON, SHERIFF 2. dur File No.: 241639 ) LVNV FUNDING LLC ) RECEIVED ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY JUN 1 8 2014 - - ) JEROME CLARK ) NO.: 10-1022 CIVIL TERM 701 STANWIX CIR APT 3 ) CARLISLE, PA 17013 ) Civil Action XXX-XX-6952 ) ) Defendant ) rn -_ , ) MEMBERS 1ST FCU and ) 7:- CORNERSTONE FCU ) ) , - Garnishee (,) =::r‘ 74A5 e -10 INTERROGATORIES TO GARNISHEE 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 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? no 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? no 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? no 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? nO T n • r 4 :• 71. 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. \res Che& 1� R P + c em m cLrdS -8. - If you are a bank or other financial instif"ution,-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. n 9. How much is the value of any property in your possession belonging to the defendant(s)? 0,00 RECEIVED 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. JUN1 $ 2014 9 Dated: iC David J. .ethaker, Esquire APOTHAKER&ASSOCIATES,P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff Our File No.: 241639 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC Plaintiff vs. JEROME CLARK Defendant CORNERSTONE FCU Garnishee COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, CO ER ONE FCU, dissolved. David J. Apothaker, Esquire Attorney for Plaintiff Ofixt sgsbpd at -44 aL#),,98.d Our File No.: 241639 APOTHAKER SCIAN P.C. By: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC Plaintiff vs. JEROME CLARK Defendant MEMBERS 1ST FCU Garnishee PROTHONOTARY 2014 JUL 24 CUNBE� NL ���D COUNTY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1022 CIVIL TERM Civil Action PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, ERS 1ST FCU, dissolved. David J. A ithaker, Esquire Attorney for Plaintiff aYc\- -PANa e))4 icq,k3& Pk3Dci(D.9