HomeMy WebLinkAbout10-7387Our File No.: 285711
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
15 SOUTH MAIN STREET STE 500
GREENVILLE, SC 29601
Plaintiff,
vs.
EMILIO PORTILLO
19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644
Defendant.
G~ THE P~'~Q ~N~d~T,~,~"~
ZOIO ~OV 30 Ate t l : 33
CUMBERCAPi~ COU~Ty~
PEt~NS YLVAN3A
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: ~ n - / 3 S~
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
34 S. BEDFORD ST.
CARLISLE PA 17013
717-249-3166
~~
S ~~ ~~
~~~ ~
Our File No.: 285711 '
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
15 SOUTH MAIN STREET STE 500
GREENVILLE, SC 29601
Plaintiff,
vs.
EMILIO PORTILLO
19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500, GREENVILLE, SC
29601
2. Defendant(s) is/are EMILIO PORTILLO, an adult individual residing at 19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644.
3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending
in 3393; and said account was issued to Defendant(s) by HSBC/ORCHARD BANK, 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 $2,029.34. 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
$2,029.34 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & AS IATES, P.C.
Attorney f Pl 'tiff
A Law Firm Enga~ d in ebt Co ctio~
BY:
David J. Apo~~cer, Esquire
Dated: 11 /22/2010
Our File No.: 285711
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 relatipgto unsworn falsification to authorities.
David J. othaker, Esquire
Attorney or Plaintiff
DATE: 11/22/2010
LVNV FUNDING, LLC
EMILIO PORTILLO
19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644
STATEMENT OF ACCOUNT
Debtor's Name: EMILIO PORTILLO
Account Number: ending in 3393
Original Creditor: HSBC/ORCHARD BANK
Balance Due: $2,029.34
Our File No.: 285711
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
Sheriff
Jody S Smith
Chief Deputy 201 Q DEC - 9 QM 4:20
Richard W Stewart CUMBERLAND COUNTY
Solicitor
PENNSYLVANIA
LVNV Funding, LLC
Case Number
vs.
Emilio Portillo 2010-7387
SHERIFF'S RETURN OF SERVICE
12/02/2010 06:02 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December
2, 2010, at 1802 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Emilio Portillo, by making known unto himself personally, at 19 Dartmouth Court,
Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $37.00
December 03, 2010
RYAN BURGETT, DEPUTY
SO ANSWERS,
RON W R ANDERSON, SHERIFF
Our File No.: 285711
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. ) NO.
EMILIO PORTILLO )
Defendant )
FILED-OFFICE
OF THE PRO THOhl ; -,.
2011 JAIN 24 P1412: ?=W
CUMBERLAND Cry
PENMSYLVAI„ ":,
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
10-7387
Civil Action
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment against Defendant, EMILIO PORTILLO, in the default of an
Answer, in the amount of $2,029.34 computed as follows:
Amount claimed in complaint: $ 2,029.34
Less: Amount Paid: ( 0.00)
Plus: Interest from November 22, 2010 to January 13., 2011
at the legal interest rate of 0.00% per annum 0.00
Attorney fees 0.00
TOTAL $ 2,029.34
I certify that Defendant, EMILIO PORTILLO, st ow-n address is 19 DARTMOUTH
CT MECHANICSBURG, PA 17055-5644.
David J. Apothaker, Esq.
Attorney for Plaintiff
Dated: January 13, 2011
Pd. IN aU Plk) k)Pamh't"
i?? a?ra?s
i? blN ???
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: EMILIO PORTILLO
19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644
COURTOF COMMON PLEAS OF
LVNV FUNDING, LLC ) CUMBERLAND COUNTY
Plaintiff )
VS. ) NO.: 10-7387
EMILIO PORTILLO ) Civil Action
Defendant )
NOTICE
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
Our File No.: 285711
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.
EMILIO PORTILLO
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 10-7387
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: January 13, 2011
Attorney for Plaintiff
Our File No.: 285711
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
COURT OF COMMON PLEAS OF
LVNV FUNDING, LLC ) CUMBERLAND COUNTY
Plaintiff )
VS. ) NO.: 10-7387
EMILIO PORTILLO ) Civil Action
Defendant )
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 19
DARTMOUTH CT MECHANICSBURG, PA 17055-5644.
We inquired with the web site of the Defense Manpower Data Center, located at 1600
Wilson Boulevard, Suite 400, Arlington, VA 22209-259i:f the Defendant(s) is/are in any
branch of the military.
Mary M. Snavely-Dixon, Director of the Defenst Mper Data Center has sent back
our inquiry indicated that the Defendant(s) is/are not in tie mrt
David J. Apothake ; 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.
4
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Mrdiy Status Report
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Corps. Air Farce, NOAA, Pahie Hearth, and Coast Ouad)-
Marv M- Srzavxly-DbuxL Director
Department of Drfease - _blaiperwer Data Center
1600 Wison &vd., Suite 300
Ativtow A 22209-259}
fht DdemrMaapaRer Data Ceuta (DhiDC) is m otgaaixataon o1 the Aeparortenr' of D4 tbat tuxtiattgns >lxe Defenu
Enro beet and EIxW Rq-rbeg System (DEERS) database a>ach is the offs a soffit of data on eligibility for miwrv medical
tar[ and other ' system.
Tbr Ruoff strongly supports the enfurcemert of dze Stine Members Civil RA d Act (50 L'SC App. §§ 501 et soy as amended)
(SCRA) tloamak known as the Solders' and Sarkrs' Civil Rxiid Act of 1930). D_-MDC bass issaed humkkeds of thousands of
'dm not possm any, iafartw oion wdcapng that dw ixdMwd is currently on active duty' responses, and has everkwed a una
ttror rate. In the evert the iockridaal referenced abcrur, or an7 fiwxl? -ember, dead, or representative assts a any manner tbat
the indmAsal is on active duty, or is odiem se eub1rd to the protections of fc SCRA, you we skoogly encowned to r#au
ft>r6a sircatiw of the pmoa's stow by eoatecAng that person't Service via tIIe'ddem tkpk mi ML
b g?vxr defenses ° ate" vr??St n If you bav a evidence the person is arc active rlut? and yrnr fat to obtain dis
additional Service VerillicMioq punitive proms cf dw SCRA essay be zr?mkedxgmtkst you. Sec 50 USC App. §521(c)-
if yore obtain additiorwl aafbmuAarc abort the person (e g, an SSNt * woved accuracy o(DM a rnidc* maxi), you can sv>6mit
your request aM at this Web site and we vol prm-Ac a nett cerblicatr far rho *Dm.
This response fdk' to active d.ty status kdxkq date the individual was last on aresrva de ty. fit wits Vibia ffir:prWA&g 367
dzys.. For Mastorica) iaformstian, please contact dbe Slice SCRA lwiots-d"-comact.
Adv e dun- stators as reported in this certi&me is dgd xd it accordance wih 10 is SC § 191 (d)(1) for a pm. d of more than 30
consecubve divs In the case of a member of the -Nativaat Cntzad. ucltdes tmicr under a call to active service aurtborized by die
Preriderat at ** $ecxetary of Ddinit foe a period of awe dunce 30 eonw--utn e
days order 32 tSC § 50.(flfor purposes CC
to a *z6onal anergtncy declared by the Presi lew and suppcared by Federal f ands All Artier Guard Rxsmr (AGR)
meiuberx nag be waig med againg an mat wwrd mob&ataon posibm in the unit tx? support This n Acdes Nav j TARS, Marne
Caps ARs and Co" Guard RPM, Active Dux, status also applies to a V4 rmed Senice member wbo is an act qv dory
conwjo siamed kal!"iter cfdw U.S, Fnblio Heath Sc ice or the',`aional 4kessic *ad Atmospheric .'l41a*istEa6m (NNO AA
Commissioned Corps) for aperiod efmorr than 3G consecutive day s.
Covernge Under 4w SCR.4 it Broout w m Some Casa
Ccniv:W under the SCRA is broader is some cases and includes some categories of persons on active duty far purposes ofdr
SCRA who wauid not be reported as on Act %r Duty utdet ties cerfcet.
'.Monty tires orders :zee amended to rx the period ofactwr duty, whA would extend SCRA protretiooa- Persons se+dung to
rdy as dis webste certfica6m shod cheek to make swe the orders on xrhie6 SCR.A protection are based have not bey
arepded to extend dw i 4wive dates of smice Forthmwore, some protections ofthe $CPA may extend to perms M%o have
wcrimd orders to report for active dory at to be inducted, but who hint ant actual y hrgm a cbm duty or acmatly reported fox
ixlwboa The Last Date on Actity Duty entry is czportwA became a marzber ofprokcbom of SCRA eaund beyond the last
dolBei o(am-t duav
Those wk would rely on this cerbficate are aged to seek ramified kgal counsel to ens re that A rigbb gunaearerd m Strw ce
taesibe rs inert the SC"RrS are protened
R'AKNM G: Tbts cafficatr was p nmidtd based on a name and SSN prm ded by Sc sapeeter. Providing an eta woos aa¢
at SS! will cause an enoot m cerficate to be provided
Report to tTDRT1HJDC
285711 OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
LVNV FUNDING, LLC )
VS. )
EMILIO PORTILLO )
To: EMILIO PORTILLO
19 DARTMOUTH CT
MECHANICSBURG, PA 17055-5644
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 10-7387
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
34 S. BEDFORD ST.
CARLISLE, PA 17013
717-249-3166
Date: December 27, 2010
BAR
DAVID J. APO HA R, 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.: 285711 f ` '
l HONOTA
LVNV FUNDING, LLC ,, ,E NOV I ci IN THE COURT OF COMMON PLEAS OF
Plaintiff t` ' $ `l 3� CUMBERLAND COUNTY,
1-L fi[3ERLA D COUNT
VS. PENNSYLVANIA
EMILIO PORTILLO NO.: 10-7387
Defendant(1)
)$1 00,..11 S PRAECIPE FOR WRIT OF EXECUTION
Toil Prothonotary: I S 1
Issue a Writ of Execution in the above matter,
(1) directed to the Sheriff of CUMBERLAND County;
(2) against EMILIO PORTILLO, defendant(s); and
(3) against M& T BANK 960 WALNUT BOTTOM RD CARLISLE, PA 17015, Garnishee(s);
(4) and index this writ in the judgment index
(a) against EMILIO PORTILLO, defendant(s), and
(b) against M &T BANK 960 WALNUT BOTTOM RD CARLISLE, PA 17015, 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 $2029.34
Interest from January 24, 2011 $332.58
Minus Payments made -$
Plus Costs $193.00
Total $2554.92
CIO g DCNI ,ebt
dd Benjamin Caval aro, Esquire
Attorney fo ' ..ntiff(s)
� ,a5� wt � -
c� a °� �� °i"� , 0 L�
Mit-
V__31 -:.(994P36S
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 10-7387 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due LVNV FUNDING,LLC Plaintiff(s)
From EMILIO PORTILLO,257 MAIN STREET, MILL HALL,PA 17751
(1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed
to attach the property of the defendant(s)not levied upon in the possession
of GARNISHEE(S)as follows:
M&T BANK,960 WALNUT BOTTOM ROAD,CARLISLE,PA 17015-ALL ASSETS AND
ACCOUNTS, INCLUDING,BUT NOT LIMITED TO, BANK ACCOUNTS, BROKERAGE FIRM
ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC.
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;
(2) 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$2,029.34 Plaintiff Paid$
Interest FROM JANUARY 24,2011 -$332.58
Attorney's Comm. % Law Library$.50
Attorney Paid$172.00 Due Prothonotary$2.25
Other Costs$ ei 3•o°
Date: 11/18/13
David D. Buell, Prothonotary
• / Deputy
REQUESTING PARTY:
Name : BENJAMIN J. CAVALLARO,ESQUIRE
APOTHAKER&ASSOCIATES,P.C.
Address: 520 FELLOWSHIP ROAD,C306
P.O.BOX 5496
MT.LAUREL,NJ 08054
Attorney for: PLAINTIFF
Telephone: 1-800-672-0215
Supreme Court ID No.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
J
Sheriff ���,,x�r at t":�Errate,��,��� '•r '�+ ; r 1-�(� ,,�, ► r; ,
Jody S Smith
Chief Deputy cwt NOV 25 ,
Richard W Stewart
Solicitor OF F} E OF_HE S�ERWr
PENNSYLVANi,
LVNV Funding, LLC
vs. Case Number
Emilio Portillo 2010-7387
SHERIFF'S RETURN OF SERVICE
11/21/2013 01:59 PM- Shawn Gutshall, 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, M &T Bank, 1 West High Street, Carlisle Borough,
Carlisle, PA 17013, Cumberland County, by handing to Yvette Shughart-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 22, 2013 to Emilio Portillo, 257
Main Street, Mill Hall, PA 17751.
GUTSHALL, DEPUTY
SO ANSWERS,
November 22, 2013 RbNW R ANDERSON, SHERIFF
t ?''ountvskmo Shallff Te'.eoscft.L'c.
Our File No.:285711
LVNV FUNDING, LLC )
COURT OF COMMON PLEAS OF
Plaintiff ) CUMBERLAND COUNTY
vs. )
EMILIO PORTILLO ) NO.: 10-7387
257 MAIN ST )
MILL HALL, PA 17751 ) Civil Action
XXX-XX-9193 )
Defendant ) M�
r-
M&T BANK ) cn
< Cn
Garnishee
Aa 5; ry ,
r F7
INTERROGATORIES TO GARNISHEE _°-
TO: M & T BANK, 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?
q Q S Q I -a4•-)�S
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)?
r-11 C3
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?
r\O
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?
,-'o
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?
1-3
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 yvou?
n
7. 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
bads 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.
('�o
8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the
defendant(s) have funds on deposit in an account in which 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. y�e 5 G,N 1 S - n o
9. How much is the value of any property in your possession belonging to the defendant(s)?
10. In the space below, the plaintiff may set forth additional appropriate interrogatories.
Dated:
Benjamin J. aro, Esquire
APOTHAKER&ASSOCIATES,P.C.
520 Fellowship Road C306
PO Box 5496
Mount Laurel,New Jersey 08054
(856) 780-1000
Attorneys for Plaintiff
CATHY S FISHER
M&T BANK
DLC c� 3 Z013
Our File No.: 285711 ,28A/ �4 PR Or 1iOI1- C-47
7-
APOTHAKER&ASSOCIATES,P.C.
Jd�23 P�1 `
By: David J. Apothaker,Esquire C(If� l 55
520 Fellowship Road C306 PF' �INQ n
PO Box 5496 t v Ol
Mount Laurel,NJ 08054
(800) 672-0215
Attorneys for Plaintiff
)
LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY
Plaintiff )
vs. )
) NO.: 10-7387
EMILIO PORTILLO )
) Civil Action
Defendant )
)
M&T BANK )
)
Garnishee )
)
PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly mark the attachment against the Garnishee, M-' T 1ANK, dissolved.
David J. Apothaker, Esquire
Attorney for Plaintiff
Sq SCYpa at,ty
e)( tk (31 Ltr)
SOC)1CA
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
w-^
QF.f CE OF THE S!4EFIFF
T;-1} rr^,OT rtU3' O
JUN 16 PM 2:35
CUMBERLAND COUNTY
PENNSYLVANIA
LVNV Funding, LLC
vs.
Emilio Portillo
Case Number
2010-7387
SHERIFF'S RETURN OF SERVICE
11/21/2013 01:59 PM - Shawn Gutshall, 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, M & T Bank, 1 West High Street, Carlisle Borough,
Carlisle, PA 17013, Cumberland County, by handing to Yvette Shughart - 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 22, 2013 to Emilio Portillo, 257
Main Street, Mill Hall, PA 17751.
06/13/2014 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: $89.26 SO ANSWERS,
June 13, 2014 RONR ANDERSON, SHERIFF
(c) CountySuie Sheriff, Teleosoff. Inc.