HomeMy WebLinkAbout10-1832LVNV FUNDING LLC
c/o Edwin A. Abrahamsen & Assoc.
120 North Keyser Ave.
Scranton, PA 18504
Plaintiff
VS.
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
NO: Ib - I 39 aiv i ITeti?^
Jennifer A Woodard
432 3RD ST
ENOLA PA 17025
Defendant PRAECIPE FOR ENTRY OF JUDGMENT
n
C N e
_
To the Prothonotary of CUMBERLAND County:
-r.+ O ?
1) Enter Judgment on the attached Certified copy of Judgment from a Dist &t Ju stke. ;
A) Date of Instrument: 10/7/09
?-: Cn c
B) Amount of Judgment: $2926.53 C
n
7
-
C) Interest From: 10/7/09
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
c/o Edwin A. Abrahamsen & Assoc.
120 North Keyser Ave.
Scranton, PA 18504
4) I hereby certify that the address of the defendant is:
Jennifer A Woodard
432 3RD ST
ENOLA PA 17025
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
120 N. Keyser Ave
Scranton, PA 18504
570-558-5510 Ext. 101
Attorney 1D 86285
Attorney for Plaintiff
d?. a5 PO
00 4858
ea 38888
COMMONWEALTH OF PENNSYLVANIA
rrnl; iniTv nr:• CUMBERLAND
Mag. Dist. No.:
09-1-03
MDJ Name: Hon.
RICHARD S. DOUGHERTY
Address: 9 8 S ENOLA DR STE 1
ENOLA, PA
Telephone: (717 ) 728-2805 17025
ATTORNEY FOR PLAINTIFF :
EDWIN A. ABRABAIIISEN & ASSOC, PC
120 N. SEYSER AV8
KICRAEL RATCHFORD, ESQ.
SCRANTON, PA 18504
NOTICE OF JUDGMENT/TRANSCRIPT
CIVIL CASE
PLAINTIFF: NAME and ADDRESS
r
LVNV FUNDING, LLC
1729 PITTSTON AV==
EDIfIN ABRARMORN & ASSOC
LSCRANTON, PA 18505
J
VS.
DEFENDANT: NAME and ADDRESS
rMOODARD, JENNIFER A
432 3RD STREET
ENOLA, PA 17025
L J
Docket No.: CV-0000271-09
Date Filed: 8/31/09
THIS IS TO NOTIFY YOU THAT:
Judgment: DEFAULT _.JUD( 't . PLTF (Date of Judgment) _ 10/07/0.9
1XI Judgment was entered for: (Name) LVNV FUMING, LLC
® Judgment was entered against: (Name) iIOODARD, JENNIFER A
IT-
in the amount of $ a, 926.5
Defendants are jointly and severally liable.
Damages will be assessed on Date & Time
1-1 This case dismissed without prejudice.
F] 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
Judgment Costs
interest on Judgment
Attorney Fees
Total
$ 2,830.03
$- 96.50
$ .00
$ .1010
$ 2,926.531
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.
OCT 0 7 2009
Date
I certify that this is a ti
IEC 01 2009 Date
%
My commission expires first Monday of January, 2012
/ Magisterial District Judge
ings c;ontal+*rt9 the judgment.
,'Magisterial District Judge P
SEAL
AOPC 315-07l`J? -Z o
DATE PRINTED: 10/08/09 2:34:00 PM
LVNV FUNDING LLC ; In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff
NO:
VS.
Jennifer A Woodard
432 3RD ST NOTICE OF FILING JUDGMENT
ENOLA PA 17025
Defendant
Notice is herby given that a money judgment in the above-captioned matter has been entered
against you in the amount of $ gaLL. 53 on Af is/to
By:
If you have any questions regarding this notice, please contact the filing party:
Edwin A. Abrahamsen & Associates
120 N. Keyser Avenue
Scranton, PA 18504
Telephone: (570)-558-5510
(Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236)
LVNV FUNDING LLC
c/o Edwin A. Abrahamsen & Assoc.
120 North Keyser Ave.
Scranton, PA 18504
vs.
Jennifer A Woodard
432 3RD ST
ENOLA PA 17025
Plaintiff
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
Defendant .
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): Jennifer A Woodard 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): Jennifer A Woodard is(are) older than eighteen years of age;
That the employment status of the defendant(s): Jennifer A Woodard is(are) unknown.
Subscribed before me this d
Jennifer Loeh Venditti/Andrea Scrivener- Notary Public
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of2
Feb-16-2010 06:24:'i9
Last First/Middle Begin Date Active Duty Status Active Duty End Date Service
enc
A
Name g
y
JENNIFER Based on the information you have furnished, the DMDC does not possess
WOODARD A any 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).
ft,may-?,..
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 et 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 http://wv,,w.de-fens-elin.k.mil/faq/pis/PC09SLDR.-htm-l. 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.
https://www.dmdc.osd.mil/appi/scra/popreport.do 2/16/2010
Request for Military Status Page 2 of2
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 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:ALIE5 I S3 SU
https://www.dmdc.osd.mil/appj/scra/popreport.do 2/16/2010
LVNV FUNDING LLC
vs.
Jennifer A Woodard
432 3RD ST
ENOLA PA 17025
vs.
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
NO: 10-1832
Defendant
WACHOVIA BANK M&T BANK
6416 CARLISLE PIKE STE 2100 28 WALNUT BOTTOM RD '
MECHAN[CSBURG, PA 17050 SHIPPENSBURG PA 17257 .
Garnishee .
t~ ~
~, ~'
~~
v7~:~ Iv ~~
.~-:.-
~~~ ~
~~
~
.~ c~:: -sa _
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r
°~ ~ ce
W ""
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~:; c~ ~
-A tJ'~1 ~ ~~
Praecipe for Entry of Appearance
Kindly enter my apeazance on behalf of LVNV FUNDING LLC in the above-captioned
matter.
Date:October 8, 2010
~int N'~me: Ml~el
Address: 120 North Kf
Scranton. Pty
Telephone No: 570 5
Supreme Court ID No:
PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a)
LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs. C 7
~:,, ,.,,,,
o C3
'Tt
Jennifer A Woodard er: cx~ ~ ~ ~
432 3RD ST NO: 10-1832 ~ ~
' -~-a ~~
ENOLA PA 17025 cQ .
~~ r,~ ~ ~
Defendant r--. o-- Q
~~
~ ~~
~~
vs. PRAECIPE FOR WRIT OF EXECU')A N~ ~;;
ATTACHMENT .Y ~
~ ~
~
WACHOVIA BANK M&T BANK
~
~ `'
~
6416 CARLISLE PIKE STE 2100 28 WALNUT BOTTOM RD ~ C3'1 ~
MECHANICSBURG, PA 17050 SHII'PENSBURG PA 17257 _
Garnishee
(MONEY JUDGMENT)
To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) Against: Jennifer A Woodard
(3) And against: WACHOVIA BANK 6416 CARLISLE PIKE STE 2100 MECHANICSBURG, PA 17050;M&T
BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257
(4) and index this writ (a) against
Defendant(s) (b) against
Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s), any and all accounts of the
defendant(s), in the possession of Garnishee, including but not limited to savings account balances; checking account
balances; Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes. Defendant's SSN(s):
199-68-5045;
O (5) Judgment Amount $2,926.53
S
#a~. so
P~ ~m Interest $99.58
a?•01,5 C~ Clerks Fee $
a•50 Sheriff $
tj~.~ -P~ Al"rY Poundage
Total
Date: October 8, 2010
$ d. oo ~ue~
• 5o u
~~ i~s-~7
~ a~A9Q3
~~~+~~
LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs. c~
~ ~
~ ~
~ ~ ~ ~
Jennifer A Woodard
432 3RD ST NO: 10-1832 ~- -•-a ~~
ENOLA PA 17025 ~ s> ~
Defendant ~ ~ ~ ;~
vs. ~ ~ c~ ~
WACHOVIABANK M&T BANK AFFIDAVIT UNDER SOLDIERS AND S~-IL6RS
6416 CARLISLE PIICE STE 2100
MECHANICSBURG, PA 17050 28 WALNUT BOTTOM RD
s1BPPENSBURG PA tns~
RELIEF CIVIL RELIEF ACT OF 1940 AS
Garnishee 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): Jennifer A Woodard; 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): Jennifer A Woodard; is(are) older than eighteen years of age;
That the employment status of the defendant(s): Jennifer A ~Yg6dar~el; ~s(are
F.
Subscribed before me this _~~day of 20~_
_._ «t
Notary ublic
NOTARIAL SEAL
LEE PERRICONE
Notary Public
SCRANTON CITY, LACKAWANNA COUNTY
My Commission Expires Apr 2. 2014
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Oct-18-2010 10:53 :59
Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
JENNIFER Based on the information you have furnished, the DMDC does not possess
WOODARD A any 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).
~. ~r-~-
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 et 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 http://www.defenselink.miVfaq/~is/PC09SLDR.html. 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.
https://www.dmdc.osd.mil/appj/scra/popreport.do 10/18/2010
Request for Military Status
Page 2 of 2
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 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:GSJN3T2OVI
https://www.dmdc.osd.mil/appj/scra/popreport.do
10/18/2010
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-1832 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LVNV FUNDING LLC, Plaintiff (s)
From JENNIFER A. WOODARD, 432 3`d Street, Enola, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
WACHOVIA BANK, 6416 Carlisle Pike, Ste 2100, Mechanicsburg, PA 17050
M&T BANK, 28 Walnut Bottom Rd, Shippensburg, PA 17257
Any and all accounts of the defendants in the possession of Garnishee, including but not limited to
savings account balances; checking account balances; Certificates of Deposit; Money Market
Accounts; countents of Safety Deposit Boxes Defendant's SSN: 199-68-5045
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) 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;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,926.53
Interest -- $99.58
Atty's Comm
Atty Paid $54.25
Plaintiff Paid
Date: 10/20/10
F
(Seal) ~ ~
...
REQUESTING PARTY:
L.L.$.50
Due Prothy $2.00
Other Costs
D uell, Proth notary
By:
Name MICHAEL F. RATCHFORD, ESQUIRE
Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
120 N. KEYSER AVE
SCRANTON, PA 18504
Attorney for: PLAINTIFF
Telephone: 570-558-5510
Supreme Court ID No. 86285
Deputy
SHERIFF'S OFFICE OF CUMBERLAND
Ronny R: Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
LVNV Funding, LLC
vs.
Jennifer A Woodard
SHERIFF'S RETURN OF SERVICE
11/02/2.010 09:39 AM'- Noah Cline, Deputy Sheriff, who being duly sworn according to
2, 2010 at 0936 hours, attached as herein commanded all goods, chattels,
monies of the within named defendant, to wit: Jennifer A. Woodard, in the h
the within named garnishee, Wachovia Bank, 604 East High Street, Carlisle
Pennsylvania, 17013, by handing to Scott Pasciak, Personal Banker, perso
interrogatories together with three true and attested copies of the writ of ex(
there of known to him.
11102/2010 09:27 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to
2, 2010 at 0924 hours, attached as herein commanded all goods, chattels,
monies of the within named defendant, to wit: Jennifer. A. Woodard, in the 1
the within, named garnishee, M & T Bank,1 W High Street, Carlisle, CumbE
17013, by handing to Joy Mathna, Senior Teller, personally three copies of
three true' and attested copies of the writ of execution and made the conten
UNTY
Case Number
2010-1832
w, states that on November
3hts, debts, credits, and
nds, possession, or control of
Cumberland County;
ally three copies of
:ution and made the contents
w, states that on November
ghts, debts, credits, and
nds, possession, or control of
and County, Pennsylvania,
terrogatories together with
there of known to her.
The writ of execution and notice to defendant was mailed on November 3, 010 to Jennifer A. Woodard at
432 3rd Street, Enola, PA '17025.
SO AN
November 03, 2010
ANDERSON, SHERIFF
ne, Deputy
c Ccu;° cute 5_e. Tefe.,.. Inc.
a `
Y 3 ?.
LVNV FUNDING LLC
VS.
Jennifer A Woodard
432 3RD ST
ENOLA PA 17025
VS.
f..
In the Court of Common Pleas of x
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
• 1 -
NO: 10-1832
Defendant
ff ?1 C
INTERROGATORIES IN ATTACHMENT W
WACHOVIA BANK M&T BANK
6416 CARLISLE PIKE STE 2100 28 WALNUT BOTTOM RD
MECHANICSBURG, PA 17050 SHIPPENSBURG PA 17257
Garnishee
RE: Execution of Judgment against your depositor Jennifer A Woodard SSN # 199-68-5045
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 subseqent time, did the Defendant possess
any bank accounts, joint or individual, that were in your custody or control?
Please specify joint or individual account. Please list the legal title of any such
account(s) an dthe primary account holder and if known whether joint account is
entireties property. ?
10 4 7,B
2) At the time you were served or at any subsequent time, what was the balance and
account number of the bank accounts(s) identified in Interrogatory #1?
3) At the time you were served or at any subsequent time, please list the average
daily balance in the past five (5) months for each such account identified in your
answer to Interrogatories number one (1) and two (2) above.
4) At the time you were served or at any subsequent time, did the bank account(s)
that the Defendant possessed contain fund derived solely from social security
funds and/or disability. funds?
5) At any time before or after you were served, did the Defendant(s) transfer or
deliver any property or money to you or to any person or place pursuant to your
direction or consent, and if so, what was the consideration therefore?
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 Depositor's
direction or otherwise discharge any claim of the Depositor against you?
U?
7) At the time you were served or any subsequent time, did you have, 'share, or
utilize any safe-deposit boxes, pledges, documents of title, securities, notes,
coupons, receivable, license, or collateral in which there was an. interest claimed
by Defendant(s)?
8) At the time you were served or at any subsequent time did the Defendant(s)accoount
contain funds deposited electronically on a recurring basis and which are identified
as being exempt from execution, levy or attachment. If so, state the reason for the
exemption, the amount being withheld and the entity electronically depositing
those funds on a recurring basis.
O;
9) At the time you were served or at any subsequent time did the defendant have funds
on deposit in an accoun in which the funds on deposit, not including any otherwise
exempt funds, did not exceed the amount of the general monetary exemption under
42 PCRRCa.C.S. Section 8123? If so, identify each account.
PJ i
10) Identify every other account (not previously noted) titled in the name of the
Defendant(s) in which you believe the Defendant(s) have an interest in whole of
part, whether or not styled as a payroll account, individual retirement account, tax
acocunt, lottery account, partnership account, joint or tenants by entirety account,
insurance account, trust or escrow account, attorney's account, or otherwise.
Ok
11) To the extent that you're above answers depend in whole or part on documents,
account records, or other papers or electronic data, describe each in exact detail
(or attach a copy of the same).
.,?sociates4 P.C.
Edwin A.,/?brahsen & A
/ Mic'e' lard, squi
120 o KKeyser Av nue
Scranton, PA CATHY B t-ibma (570) 558-5510 E t. 101
M&T BANK
LVNV FUNDING LLC , C-D
-
SEARS PREMIER CARD In the Court of Common Pleas of ' F
Plaintiff CUMBERLAND County, Pennsylva#>a
Civil Division ' ?r=
VS. '
Jennifer A Woodard
432 3RD ST NO: 10-1832
ENOLA PA 17025 w?
r ? r
yWti
Defendant
Praecipe to Dissolve the Attachment again st
vs. Garnishee
WACHOVIA BANK
6416 CARLISLE PIKE STE 2100
MECHANICSBURG, PA 17050
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
Michael F ( Ratchford, Esqui e
Edwin A. Abrahamsen & soc' tes, P.C.
Lawyer ID # 86285
Sworn and subscribed efore me on this /tO day of N0Ve0,b&'- 20/0
Notary Public
NOTARIAL SEAL
MARTHA J BACHMAN
Notary Public
SCRANTON CITY, LACKAWANNA COUNTY
My Commission Expires Apr 29, 2014
r or.)
ts Is
0'o ?O
LVNV FUNDING LLC 3 ri p
SEARS PREMIER CARD In the Court of Common Pleas of Lnr -M
Plaintiff CUMBERLAND County, Pennsylv;4., x" o d
Civil Division
VS. 3[
Jennifer A Woodard cn
432 3RD ST
NO: 10-1832
cil
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--.;
ENOLA PA 17025
Defendant
Praecipe to Dissolve the Attachment against
vs. Garnishee
M&T BANK
28 WALNUT BOTTOM RD
SHIPPENSBURG PA 17257-8219
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
Mieffael F. Ratchford, E uio
Edwin. A. Abrahamsen Associates, P.C.
Lawyer ID # 86285
V-il
Sworn and subscribed before me on this
day of 20/6
Notary Public
=Pubblic
SCRANTOPJ C??q GOUNTY ?aDA.
My Gornn?ir 2, 2014 41
00 C? ?o g 2
SHERIFF'S OFFICE -OF CUMBERLAND COUNTY
Ronny RAnderson r ILEU-OFFIC
Sheriff r;T !
at `ir,nG, H;7 PiR0TMpr???:, ,
4VCrtlf, ??a?l? ,Ap
Jody S Smith "P
Chief Deputy 2 PH 2;
Richard W Stewart CU BERLA?
Solicitor oFf PENNSYLVANIA rY
LVNV Funding, LLC
vs. Case Number
Jennifer A Woodard 2010-1832
SHERIFF'S RETURN OF SERVICE
11/02/2010 09:39 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on November
2, 2010 at 0936 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Jennifer A. Woodard, in the hands, possession, or control of
the within named garnishee, Wachovia Bank, 604 East High Street, Carlisle, Cumberland County,
Pennsylvania, 17013, by handing to Scott Pasciak, Personal Banker, 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 him.
11/02/2010 09:27 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on November
2, 2010 at 0924 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Jennifer A. Woodard, 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 to Joy Mathna, Senior 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 November 3, 2010 to Jennifer A. Woodard at
432 3rd Street, Enola, PA 17025.
08/31/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $91.17
August 31, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
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