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Home My WebLink About11-0310Our File No.: 283341 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 PORTFOLIO RECOVERY ASSOCIATES, LLC 140 CORPORATE BOULEVARD NORFOLK, VA 23502 Plaintiff, VS. LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 Defendant. RLEG-01 1 10 E 2111,JN13 FM 2:0"1 C"UMBERLAI D C0UNF_ PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ))- 316 No I 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 ,l$ 717-249-3166 C # ?3G 3a * *#&41, ? /2111 a53W y Our File No.: 283341 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 PORTFOLIO RECOVERY ASSOCIATES, LLC 140 CORPORATE BOULEVARD NORFOLK, VA 23502 Plaintiff, VS. LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC, 140 CORPORATE BOULEVARD, NORFOLK, VA 23502. 2. Defendant(s) is/are LAURA K AMSPACKER, an adult individual residing at 23 S 39TH ST CAMP HILL, PA 17011. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account # ending in 3777; and said account was issued to Defendant(s) by FIA CARD SERVICES/BANK OF AMERICA, 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 $5,972.66. 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 $5,972.66 and requests this Court award costs to the extent permitted by applicable law. APOTH=R & A SOCIATES, P.C. Atto ey f Plaintiff' A Law Firm En aiz in D t Collection BY: David J. Apothaker, Esquire Dated: 12/23/2010 Our File No.: 283341 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 P, to authorities. DATE: 12/23/2010 liavia .i. ApomaKer, -,squire Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 283341 LAURA K AMSPACKER ending in 3777 FIA CARD SERVICES/BANK OF AMERICA $5,972.66 EXHIBIT "A" .285341 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: PORTFOLIO RECOVERY Expiration Date: ASSOCIATES, LLC Type of Action: Civil Action Defendant/s: LAURA K AMSPACKER Serve Upon: LAURA K AMSPACKER Address for Service: 23 S 39TH ST CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 4` ' Our file No.: 283341 ./ Cly Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, VS. LAURA K AMSPACKER 'ROTHONOTAi ',` ,` J G 2011 MAR 18 Pty 2: 42 r") C'UMBERLAND COUNTY PENNSYLVANIA , COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 11-310-CIVIL Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on February 28, 2011, STIPULATED by and between PORTFOLIO RECOVERY ASSOCIATES, LLC ("Plaintiff') and LAURA K AMSPACKER ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $5,972.66, plus court costs in the amount of $133.50, for a total of $6,106.16. 2. Defendant agrees to pay to Plaintiff the sum of $5,972.66, plus court costs in the amount of $133.50, for a total of $6,106.16; which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $506.16 to be paid on or before February 28, 2011; b. $400.00 to be paid on or before the 30`h day of each month, beginning March 30, 2011 until paid in full. 5. All checks shall be made payable to "PORTFOLIO RECOVERY ASSOCIATES, LLC", and sent to the office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 1 41-11 In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and the default is not cured within ten (10) days, then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant in the suit amount, plus court costs, as specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application, with supporting certification, and with notice to Defendant in the form of a copy of the application addressed to Defendant by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. By: Y AMSPAC kKUx Defendant 2 Apothaker & Associates, P.C. Attorneys for Plaintiff Our File No.: 283341 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 . _" 'F"LAFD COUNT?1' ='EH .3SYLn' t lA PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. LAURA K AMSPACKER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-310-CIVIL PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, and against Defendant, LAURA K AMSPACKER, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on March 18, 2011, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of: Balance: Less: Payments: Plus: Interest from March 18, 2011 TOTAL Dated: October 14, 2011 David J. Apotl Attorney for P Civil Action $ 6,106.16 ( 2,506.16) .00 $ 3,600.00 , Esq ,A % 14 oo al a ley C 3) S01 l / 97 5 ??01 (yiai Our File No.: 283341 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 PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. LAURA K AMSPACKER 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 March 18, 2011, 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 $6,106.16, giving the Defendant credit for payments made totaling NO.: 11-310-CIVIL $2,506.16, for a total of $3,600.00. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalti s bf 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apoth e , sq. Attorney for Plaintiff Dated: October 14, 2011 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. LAURA K AMSPACKER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-310-CIVIL Civil Action 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. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT ? JUDGMENT BY DEFAULT ? JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION ? JUDGMENT FOR POSSESSION ? JUDGMENT ON AWARD OF ARBITRATORS IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 Our File No.: 283341 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 PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. LAURA K AMSPACKER Defendant NO.: 11-310-CIVIL 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 23 S 39TH ST CAMP HILL, PA 17011. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 2220 593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the fens Manp er Data Center has sent back our inquiry indicated that the Defendant(s) is/are n in th mil' ry. David J. ApotTaker, 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. Depettment of Dtfeost Manpower Data Center def - a ? -'£} 1 1 11 1,:c 4 1<1Trary Brutus Report Ptrvuant to du Service Membem Chi kdd Act < Lust N2 a* F'InIA!>f MW IWOk palls AVI" Ditr sutm Aids's Dtssy tart Date A?rnCp AivfSPACIti ER' LAURA K Sued on ibt nkrnw for you have funiAed. tic DM3DC does "possess w irsfatmarioat in&ai" the W h dual saran L pm "dog the irkromwes dab ba *t of d* Depsr+ment afDeleim.Manpower Daft Gaut, bused an the istmuls ttt that ti'oa prrndded, dw abo%v is fix ctneat voters c( dw *A*rir W u to d broaches of the L tt7otmed Services (Army, \ avy, ti%Wine Corps,.Aa Force. -NOAA, Pubic Heath, and Coast Guervi). Nut A 4A+4?w_ 'riay M. Sae *-1. aca, Director Dept of D4mse - r_ SapoartrDtrtaCaller 1600 R-*,,= RI.d: Smite 400 Ariag m VA 22109-250 The Definse Manpower DM Ce nter (MOC) u as o4pammoa oft1w Depwaneve of Defease Halt romu as else Defense Earb6eerffi nod Eigtbky Repm*g System (DEERS) drhbae tsi3ich is the acid source d data an rigidly far m&ay mevicA care add athta dew sue. T1sc DoD strongly snpp" dw aahmemerr of rbe Sm," Mccuben CM Rad Act (50 USC App- §§ 501 et scq, as amended) (SCRA) (krdtn y immv ai the Solders' and Sai?rrs' Civti ReW Act of 19-W) DSIDC lies asued backeds Of6dwamb of 'dies ax possess nay i ifix - 0ioo iAcaeag tar the ii4vAii is curra* as scoise AW respoasns, and has eager weed a error rata In dos event 6a iaditaidaslrdmvnced abate, or u n fit* member, **ad, or representative wswts is any manner deed the itd itidittrtt is on rctim Asy, tar it odwmise eaedcd eo the protections of the SCRA, your we strco* entaueaged to obtain furdw vwdcaO0a of tic par9*6 xWo by coetactieg t/a peraati % $crvica Yk the "dt£ts'wfidLwr URL hero drww-ty pCf?4SLDR total S Yom kWni TVWWce dw pcrsw a oa tsctir c dwr ad ? oa fai to obtain this aMbonal Service verfica bw pam6m paommom of the SCRA may be evoked ap a st you, Sec 50 GSC App. §521(c). if you obtasa adciaooai viam bass about the person (e.&, an SSi .. inspmdved accartacp of DC)B, a she naaae} you can sabuto -ter request again at d is b'l'eb site and we w3 provide a new certt'6caoc for tart gmry_ This roast st*t .'ts active daarstarw inciadMSg da" else iodividud asss fast on wive dote. fit was ssidw tAe prec 36- days- Far historical information. pirew contact the Service SCRA paints-of-coatnd ,Darr iKfanra dom on "Aedsst Duty .Staters" Acme d ity status as reported in this certificate is de6rscd in atcardaece with 10 t1SC § 101(d)(1) for a period ai more than 30 ,_onserum a dr s In the case of a merobes of the Nalio" Guard, itsrlAm service under a cal to active semen arrhortced b tiro Prerideto or the St reran of Defertse for z period of ruore dram 3O curaecutivt says voider 32 USC § S()' for ptrpc ;rs of responding to a aad oral emergency declared by rfie PrmOeat and sapportsd by Fed" funds. At Actin Gerard ResenT (AGR) members muse be assigned ap ost m attborired m6bi tahm pus in the unit the} support. This mckKk-% Nn v TARS. Nfww Corps ARs and 0 oast Canard RPPAs Ame Duty states abo appies to aUntarmed Service member who is w acrasr dw eartaissiuaed oHica of tar Z S Pu1>tic Health Serice or No Cotaessiancd Carps) fix a per cd of mere tlsan 30 tcrosegsrtk'r dirs. Corrrrrge Under dlte SCR-4 is Broader in Some Carps Cm-erage render the SCRA is broader m some cases and indnies some categories of persons on active &r fix purposes oftise SC? ,A b, ?,geld w( br tqpatttd won Actis,r Ustc trader dis cettifit'ate. \-iarr? tones orders are Mnradcd to extend the period ciacti -e fir}, -.%i h would vamd SCRA protecocros r n,am scelaag to rch ou (Iris %N411te cntifrcatkin should check to malice sue die orders on tivl" SCRA protections arc tmw3 hart not been atxsM&d to eNtrgd the mciirsne date; of seyt er Ftndhtrttwre, same proteoms of for SCRA ma:° ettrad tai p't . ms xh,'', hour xecon ed orders to repot doe azw e drt' or to be axtucted, but who hzc not actuav begtm acm-r drat} cr actu*. rctxortLd for sn criers. Tice Lao Date n .4cti. r Dot, envy k irnponaw because a masher of protections of SCR c -rvd k- cod the art date s a,-m- dime These tistre would rdY on this ce:rtikate me urged to seek quabhod kgad cotatscl tc cur,&c that al rights guwaaterd w Scr we verrAsers under OK- SCRA art ps'otected W.ARN7INC, This certificate was proNided based an a name and SSN pro dni bv the rerErnester. Prmirlrng an erronecrus name c4 SS\ iO tjw, = rtvAle un certificate tc be pTo?ldt-:1.. Reprise 'D , D? R -,, R't"D Our file No.: 283341 Apothaker & Associates, P.C. 520 Fellowship Road 0306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, VS. LAURA K AMSPACKER Defendant. 9 r i' I 1 ?42 ,,,::MBE R? AND COUNTY pENNSYLVANIA O ry 1 'lop i \ f \ COURT OF COMMONS PLEAS CUMBERLAND COUNTY DOCKET NO.: 11-310-CIVIL Civil Action STIPULATION IN LIEU OF The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on February 28, 2011, STIPULATED by and between PORTFOLIO RECOVERY ASSOCIATES, LLC ("Plaintiff') and LAURA K AMSPACKER ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $5,972.66, plus court costs in the amount of $133.50, for a total of $6,106.16. 2. Defendant agrees to pay to Plaintiff the sum of $5,972.66, plus court costs in the amount of $133.50, for a total of $6,106.16; which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $506.16 to be paid on or before February 28, 2011; b. $400.00 to be paid on or before the 30"' day of each month, beginning March 30, 2011 until paid in full. 5. All checks shall be made payable to "PORTFOLIO RECOVERY ASSOCIATES, LLC", and sent to the office of Plaintiffs attorney, Apothaker & Associates, P.C., located at the following address: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 1 In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and the default is not cured within ten (10) Clays, then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant in the suit amount, plus court costs, as specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application, with supporting certification, and with notice to Defendant in the form of a copy of the application addressed to Defendant by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. By. B J. 4aaro,Esquiir*e Attorne07949 Apothaker & Associates, P.C. Attorneys for Plaintiff URA K AMSPACK Defendant WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-310 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff (s) From LAURA K. AMSPACKER, 23 SOUTH 39TH STREET, CAMP HILL, PA 17011 (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: SOVEREIGN BANK, 269 PENROSE PLACE, CARLISLE, PA 17013 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 $3,600.00 Interest FROM OCTOBER 21, 2011 - $149.13 L.L. $.50 Atty's Comm % Arty Paid $179.00 Plaintiff Paid Date: 7/5/12 (Seal) REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD C306 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 800-672-0215 Supreme Court ID No. 38423 Due Prothy $2.25 Other Costs $193.00 David D.BBuell, Prothonotary ?f Deputy Our File No.: 283341 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY COMMONWEALTH OF PENNSYLVANIA G o PORTFOLIO RECOVERY ASSOCIATES, -r N r LLC Z ? VS. NO.: 11-310-CIVIL C. G? LAURA K AMSPACKER C 23 S 39TH ST PRAECIPE FOR WRIT OF EXECUTION . CAMP HILL, PA 17011 (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLANDCounty, PA; (2) against LAURA K AMSPACKER, Defendant(s) (3) and against SOVEREIGN BANK 269 PENROSE PLACE CARLISLE, PA 17013, Garnishee(s) (4) and enter this writ in the judgment index (a) against (b) against Defendant(s) and Defendant(s) and as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s). Specifically describe l per attached property description: (5) Amount Due Interest from October 21, 2011 (Costs to be added) Payments Dated: ?H l( V 41. sr--) eff ?a.00 ?ll? I ?-l . o U lc ?? ?.so%L `'a °11a'C)o Td $3600.00 $149.13 $193.00 $0.00 C? (199 a7-7Uol David J. Apothaker, Esq. Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Supreme Court ID No.: 38423. of U.-J;k rr r*i a CD -4 I- 5 Rtj SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor &OW" '3f ?au?ftt r b I ifE P R 0 1 (t0"#U1 2012 JUL 16 Ali 8: 48 CUMBERLA O COUNT` PENNSYLVANIA Portfolio Recovery Associates, LLC Case Number vs. Laura K. Amspacker 2011-310 SHERIFF'S RETURN OF SERVICE 07/11/2012 10:11 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 1 , 2012 at 1005 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and mo ies of the within named defendant, to wit: Laura K. Amspacker, in the hands, possession, or control of the within named gamishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylva is 17013, by handing to Denise Beecher, Teller, personally three copies of interrogatories together with t ree 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 July 12, 2012 to Laura K. Amspacker at 2 S 39th Street, Camp Hill, PA 17011. SO ANSWERS, July 12, 2012 R ANDERSON, SHERIFF (c) CountySutte Shenft, Teleosoft, Inc. William Cline, Deputy Our File No.: 283341 PORTFOLIO RECOVERY ASSOCIATES, LLC vs. Plaintiff LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 XXX-XX-8885 SOVEREIGN BANK COURT OF CgMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-310-CIVIL Civil Actions r ? cn r` w o ? :X "?F Q Cr INTERROGATORIES TO GARNISHEE TO: SOVEREIGN BANK, Garnishee: You are required to file answers to the following Interrogatories within twenty (20) days after service upon to do so may result in judgment against you. Failure I. 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 o in the joint possession, custody or control of yourself and one or more persons any property of any nature owned sol ly or in part by the defendant(s)? YES-SEE ATTACHED 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? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property i 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 defenda t(s) against you? NO 7. If you are a bank or other financial institution, at the time you were served or any subsequent ti ne did the defendant(s) have funds on deposit in an account in which funds are deposited electronically on a recurri g basis and which are identified as being funds that upon deposit are exempt from execution, levy or attach 'In ent under NO Defendant Garnishee 1 ??` I d1 .PQILG •sat.towu20uom alut.zdoiddu luuotlippu quoj ias Xujyjureld agl `moloq aouds alb ul amvLlv axs ON js)juupuajap agj of 2ui2uolaq uoissassod .moS ui 14iodwd Xuu io anlun aql St gonw off •junooou goua ?JRuapt `os JI 6£Zl8§-S'D'VdZt, .tapun uoilduuoxo lutaua2 agljo junowu oqj paaoxo jou pip `s unj Idmaxa asiAuc)glo Cuu 2uipnloui ;ou `jisodap uo spunj aql goigm ut lunooou uu ut psodop uo spunj anuq (s)Iuupu jap agj ptp aunt luanbasgns Xuu ju io poAios onm no,? owil aqj ;u `uounvisut lutouuug .tagio .ro juuq u aau n X 3I ON •stsuq 2ut.unoaa u uo spunj asogj 2utjtsodap ,?lluo?uot;bala Spluo aqj puu uoildwaxa aqj ioj uosua.t agj aluls puu ;unooou qoua ?pquopt `os jI 6mLl lu?.iapaJ 10 utulinlXst$uad OI 6 .8 JJ!IU!Bld.to3 sXau. 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Plaintiff LAURA K AMSPACKER SOVEREIGN BANK Defendant Garnishee NO.: 11-310-CIVIL, ..~ ~~"~' - r: ~ r„~ _. . ,. ~ ~,`. ~-~r~~ ~ -_~~., ;~ -a~ -, ~ T-- ~,r; - ~ ..-~. .. _ ~ ~l. ;-, ~ ~ r.;,.. _r, .~ , :,-, PRAECIPE TO ENTER JUDGMENT AGAINST THE GARNISHEE TO THE PROTHONOTARY: Enter judgment against the garnishee: SOVEREIGN BANK for the follo~ying property oCthe defendant admitted in his answers to interrogatories to be i~~ said garnishee's possession in the amo t f: $759.12 ~` David J. Apothaker APOTHAKIR & ASSOCIATES. P.C. a~~ ~ I~• 5~~~~d ~ ~ ~ a~~~ S~ '~~~ ~ofi~~ Our File No.: 283 341 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PF.NNS~"LVANIA y CIVIL ACTION -LAW TO: SOVEREIGN BANK 269 PENROSE PLACE CARLISLE. PA 17013 PORTFOLIO RECOVERY ASSOCIATES, LLC vs. Plaintiff LAURA K AMSPACKER SOVEREIGN BANK Defendant Garnishee NO.: 11-310-CIVIL NO~T~ICE IS GIVEN THAT A JUDGMENT IN THE ABOVF. CAPTIONED MAT~f[;R HAS BEEN EN'I~ERED :1(~A.INST YOC!. .~ David D Buell PROTHONOTARY II~ YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE. PLEASE CONTACT: David .i. Apothaker, Esc . Attorney for Plaintiff A Law h'irm Engaged in Debi Collection 520 Fellowship Road 0306 Mount Laurel. NJ 08054 800-672-0215 Our File No.: 283341 IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY COMMONWEALTH OF PENNSYLVANIA PORTFOLIO RECOVERY ASSOCIATES, LLC vs. LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 NO.: 11-310-CIVIL PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER. (1) Directed to the Sheriff of CUMBERLAND County, PA; 147, -?- PI .-J (2) against LAURA K AMSPACKER, Defendant(s) (3) and against SOVEREIGN BANK 269 PENROSE PLACE CARLISLE, PA 17013, Garnishee(s) (4) and enter this writ in the judgment index (a) against (b) against Defendant(s) and Defendant(s) and ,R as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s). Specifically describe property per attached property description: (5) Amount Due $3600.00 Interest from October 21, 2011 $228.06 (Costs to be added) $388.50 Payments $759.12 O A'r'ty Dated: t(?tit ll/? q1.' 0 50 CQF 99, 00 " 14.00 aq. 00 llo • 50 aao2.00 - Po A TTY -4a.a5 &X & Apothaker & Associates, P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Supreme Court ID No.: 38423. 0* 6990q &J8,07y WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-310 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES, LLC, Plaintiff (s) From LAURA K. AMSPACKER, 23 S 39`h Street, Camp Hill, PA 17011 (l) 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: SOVEREIGN BANK, 269 Penrose Place, Carlisle, PA 17013 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 $2,840.88 L.L. $ Interest from 10/21A I - - @228.06 Atty's Comm % Due Prothy 2.25 Atty Paid $222.00 Other Costs Plaintiff Paid Date: 12/20/12 avid D. Buell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQURIE Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD C306 PO BOX 5496 MOUNT LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 800-672-0215 Supreme Court ID No. 38423 Our File No.: 283341 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011 XXX-XX-8885 Defendant SOVEREIGN BANK. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 11-310-CIVIL Civil Action a No J? i co C71) y, C w u. Garnishee Sj rs INTERROGATORIES TO GARNISHEE TO: SOVEREIGN 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. I . 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)? YES, SEE ATTACHED 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? NO 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 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 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. NO 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. NO 9. How much is the value of any property in your possession belonging to the defendant(s)? SEE ATTACHED 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. N/A Dated: 11 -A David J. Apothger, Esquire APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff ANSWERS TO INTERROGATORIES Account # 1684307075 Balance: $0.00 Account Holder: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank s By: John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEATbF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PORTFOLIO RECOVERY ASSOCIATES LLC vs. LAURA K AMSPACKER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s)- Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows. David J Apothaker, Esquire Apothaker & Associates, PC 520 Fellowship Road C306 Mount Laurel, NJ 08054 Service by certified mail addressed as follows: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 V.hn . Gomes Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 January 22, 2013 IN THE COURT OF COMMON PLEATbF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PORTFOLIO RECOVERY ASSOCIATES LLC vs. LAURA K AMSPACKER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s)- Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows. David J Apothaker, Esquire Apothaker & Associates, PC 520 Fellowship Road C306 Mount Laurel, NJ 08054 Service by certified mail addressed as follows: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 ?hn S. Gomes - O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 January 22, 2013 n7/t_a??.t a ?.?•. • a. a?, ?•?yv cgs 730 1020 -* --' irngn.-n..?l ra005/009 lL > VrI. I?{Uti J I:?'iL Our bile No.: 283341 ?j4' FJvifl P? 2• t t°1 t?Lla'l COUt?T PORTFOLIO RECOVERY ASSOCIATES,' ??lAidlA JJLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ? LAURA K AMSPAC:KFK ) NO.: 11-310-CWTf, 23 S 39'I'l l ST ) CAMP I TILL, PA 17011 ) Civil Action XX.X-NN-8885 ) Defendant SOVP,RETGN TANK Garnishee .k'afsf SUPLEMENTAL INTERROGA'I'OKLES TO GAIiNISllL+'L<<' TO: SOVEREIGN BANK, Garnishee: You axe 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. I. At the time you were served or at any subsequent time did you owe the defendant(s) ally money or were you liable to def'ondant(s) on any negotiable or other written instrument, or. did defendant(s) claim that. you owed defendant(s) any money or were liable to detondant(:a) 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 volely or in part by the detendant(s)? YES, SEE ATTACHED 3. At the time you were served or any subsulucnl time did you bold legal. title lo any property <:?f Any nature owed solely or in part by the defendant(s) or in which the defcndanl bold or claimed any i nterest'l NO 4. At the tilde you were solved or at any Subsequent time did you hold as fiduciary any property in which Lhc defendant(s) had any iutcrC3t? 5. AtOany time before or after you were served did the defendant(s) transfer or deliver any properly io you or to any person or place pursuant to your direction or consent and what was the consideration Ihcr?:ol? . NO ^.?!'_?!. ?° ^?. AY 055 780 1020 F<?o06/009 6. At any tune after you were served did you pay, transfer or deliver any money or property to the defendant(s) or to say person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant(s) against yowl NO 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 dcpositcd electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or al.lachment under Pennsylvania or Federal law? If so, identity each account and state the reason for the exemption and the entity electronically depositing those Binds on a recurring basis. NO R_ If you are a bank or other financial institution, at the time you were served or at any subsequent time ilia the defendant(s) have Funds can deposit in an acu3unt in which the funds on deposit, not including any otherwise exetnpt funds, did not exceed the arnount of the general exemption under 42PA.C.S.Q81237 if so, identify each account. NO 9. Flow much is the value of any property in your possession belonging to (he defendaaut(s)? SEE ATTACHED 10. "In Lhe space below, the plaintitt' may set forth additional appropriate interrogatories. N/A Dated- ? (-? I o David 3'. Xp-othak-er, Esquire APOTTTAKFR & ASSOC'TATF,S, P_C'_ 520 Fellowship Road C306 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for:Ph intitf ANSWERS TO INTERROGATORIES Account # 1684307075 Balance: $0.00 Account Holder: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: t John S. Gomes C.O.P. Lead Specialist OF COMMON PLEAS OF CUMBERLAND COUNTY, IN THE COURT PENNSYLVANIA IN RE: PORTFOLIO RECOVERY ASSOCIATES LL VS. LAURA K AMSPACKER CERTIFICATE OF SERVICE certi that on or before the date of filing the following documents(s): I hereby fY to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Answers Execution, Claim for Exemption Order and Claim for Exemption h of the following persons in the manner I have served a copy thereof on eac indicated below: Service by first class mail addressed as follows. David J Apothaker, Esquire Apothaker & Associates, PC 520 Fellowship Road C306 Mount Laurel, NJ 08054 Service by certified mail addressed as follows: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 1. ohn S. Go es C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 February 14, 2013 Our File No.: 283341 !, ';�tg , � APOTHAKER&ASSOCIATES,P.C. Zt� MAR S Z• ZZ By: David J. Apothaker,Esquire 520 Fellowship Road C306 , �a�1NT �y Mount Laurel,NJ 08054 PE'N i5�'LVQ tiA (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ) COURT OF COMMON PLEAS OF ASSOCIATES, LLC ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 11-310-CIVIL LAURA K AMSPACKER ) Civil Action Defendant ) SOVEREIGN BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, SOVE GN BANK, dissolved. David J. Apothaker,Esquire Attorney for Plaintiff �/9a3 rw 7?S?' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-310 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC Plaintiff(s) From LAURA K.AMSPACKER,23 S.39TH STREET,CAMP HILL,PA 17011 (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: SOVEREIGN BANK,269 PENROSE PLACE,CARLISLE,PA 17013 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$:sVqaq16 Plaintiff Paid$ Interest FROM OCTOBER 21,2011 -$323.83 Attorney's Comm. % - Law Library$ Attorney Paid$260.50 Due Prothonotary$2.25 Other Costs$5 71.00 Date:JUNE 1,7,2013 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name :DAVID J.APOTHAKER,ESQUIRE Address:APOTHAKER&ASSOCIATES, P.C. 520 FELLOWSHIP RD C306 MT.LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. Our File No.: 283 341 PORTFOLIO RECOVERY ASSOCIATES, LLC IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. LAURA K AMSPACKER R)lp S NO.: 11-310-CIVIL Defendant(s) PRAECIPE FOR WRIT OF EXECUTION 'r; To the Prothonotary: -00:�[ Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; C) (2) against LAURA K AMSPACKER, defendant(s); and (3) against SOVEREIGN BANK 269 PENROSE PLACE CARLISLE, PA 17013, Garr Ashee(s); (4) and index this writ in the judgment index (a) against LAURA K AMSPACKER,defendant(s), and (b) against SOVEREIGN BANK 269 PENROSE PLACE CARLISLE, PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of Gamishee(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 $3600.00 - .2840.88 Interest from October 21,2011 $323.83 Minus Payments made $759.12 Plus Costs $577.00 Total $3741.71 9D David J. Apothaker, Esquire Attorney for Plaintiff(s) 01 .60 L t1 LO .19 -60 its # 60, 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart t-n OPc,'ZE OF THz S4CR1Fr: Solicitor C:) CrN Portfolio Recovery Associates, LLC CD Case giiber:7 vs, 2011-3'+0 C:' Laura K.Amspacker < SHERIFF'S RETURN OF SERVICE 06/21/2013 09:27 AM-Jamie DiMartle, Deputy Sheriff,who being duly sworn according to law, states that on June 21, 2013 at 0927 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Laura K.Amspacker, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Benjamin Stone, 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 him. The writ of execution and notice to defendant was mailed on June 25, 2013 to Laura K.Amspacker at 23 S 39th Street, Camp Hill, PA 17011. J DIMARTLE, DEPUTY SO ANSWERS, June 25,2013 RbNO R ANDERSON, SHERIFF (C)County Suite Sheriff, ejeoroft,111C. Our File No.: 283341 PORTFOLIO RECOVERY ASSOCIATES, LLC ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY VS. ) LAURA K AMSPACKER ) NO.: 11-310-CIVIL 23 S 39TH ST ) CAMP HILL, PA 17011 ) Civil Action XXX-XX-8885 ) ' Defendant CD SOVEREIGN BANK ) r`----;z ° -r Garnishee ) =° INTERROGA ORIES TO GARNISHEE TO: SOVEREIGN 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? 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)? YES 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? NO 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 clairn of the defendant(s) against you? NO 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 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. NO 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. NO 9. How much is the value of any property in your possession belonging to the defendant(s)? SEE ATTACHED 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. N/A Dated: David J. othaker,Esquire APOTHAKER&ASSOCIATES,P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff ANSWERS TO INTERROGATORIES Account# 1684307075 Balance: $0.00 Account Holder: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 VERIFICATION I, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: John S. Gomes C.O.P. Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. LAURA K AMSPACKER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: David J. Apothaker, Esq. Apothkar & Associates PC 520 Fellowshiip Road, C306 Mount Laurel, New Jersey 08054 Service by certified mail addressed as follows: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 1 701 1-4203 ohn S. Gomes C.O.P. Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 July 5, 2013 09/11/2013 WED 13-- 56 FAX 856 780 1020 --- sovereign 0014/015 V /5 0 ICE Our file No.: 283341 2013 S1-p T86'yo tft� I,OxrF0L10 REC OV-PPy ASSOCIAXES, LA LILC PQ�s y-NO C,01,Nr COURT WfQM�N PLEAS OF Plaintiff CIJMBFRJAND, COUNTY vs- LAURA K AMSPACFEk NO.: 11-310-ClVlL 23 S 39fli ST CAMPHILL,PA 17011 Civil Action xxx-xX-8885 Defendant -SOVEREIGN BANK Garnishee SUPPLEMENTAL TNTERROCATORIE S TO GARMSHRri, TO: SOVEREIGN BANE, (3arnisliee: You are required to file answers to the following Interrogatorier, . 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 dcfendant(s) on any negotiable or other written instrument, or did defendant(s) claim that you owed defendanks)any money or were I iahle to d0fendant(s)for any reason? NO 2. At the time you were served or at any-subsequent time wits 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)? YES" 3. At the tittle you we*re served or any subsequent tune did YOU hold legal title to any property of any nature owed solely or in part by the dc!'exidant(s) or in which the defendant held or claimed any interest? NO 4. At the time You were served or at any subsequent time did you hold as fiduciary any property in wh ic), the dcl[cridant(s)had any interest? NO 5. At any time before'or after you were served did the defendant(s)transfer or deliver any property t o you or to any person or place pursuant to your direction or consent and what was the consideration thereot? NO . r �ul.5 WNU 13: 57 FAX 856 780 1020 -- sovereign 0015/015 6. At any Lime 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 defendani(s)against you? NO 7. If you are a bank or other financial institution,at the tune you were served or any subsequent time did the defendant(s) have funds on deposit in an 11CCOUnt 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 cinder Pennsylvania or Federal law? If so, identify each account and state the reason for the exemption and the entity elcotronically depositing those funds on a recurring basis: . NO 8. If you are a bank or other I'mincial institution, at the time you were scrvcd or at.any subsequent time did the dcfcndant(s) have fiends on deposit in an account in which the funds on deposit; not including any otherwise exempt hinds, did not exceed the amount of the general exemption under 42PA.C'.S.§8123? Ir so,identify each account. NO 9. Now much is the value of any property in yuur possession belonging to the defendant(s)? SEE ATTACHED 10, In the space below, the plaintiff may set forth additional appropriate interrogatories, NIA Dated: T.?ttvid J. ltcr, Lsgttirc APQTHAKER&ASSOCIATES, P.C. 520 Fellowship Road 0306 PO Box 5496 Mount Laurel,New Jersey 08054 (856)780-1000 Attorneys fior Plaintiff ANSWERS TO INTERROGATORIES Account# 1684307075 Balance: $0.00 Account Holder: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 VERIFICATION 1, John S. Gomes, C.O.P. Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank By: . n John S. Gomes John Lead Specialist IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ' IN RE: PORTFOLIO RECOVERY ASSOCIATES, LLC VS. LAURA K AMSPACKER CERTIFICATE OF SERVICE I hereby certify that on or before the date of filing the following documents(s).- Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following indicated below: persons in the manner Service by first class mail addressed as follows: David J. Apothaker, Esq. Apothkar & Associates PC 520 Fellowshiip Road, C306 Mount Laurel, New Jersey 08054 Service by certified mail addressed as follows: LAURA K AMSPACKER 23 S 39TH ST CAMP HILL, PA 17011-4203 ?Jh S. 6o s . . Lead Specialist Sovereign Bank MA1 MB3-02-10 2 Morrisey Boulevard Boston, MA 02125 September 12, 2013 ;. t�yy iliCL. Our File No.: 283341 APOTHAKER & ASSOCIATES, P.C. Z OCT 3 ' 2. if] By: David J. Apothaker, Esquire 520 Fellowship Road C306 PMBERL ENNS YLO COU NT'Y` PO Box 5496 Ati;A Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff ) PORTFOLIO RECOVERY ) COURT OF COMMON PLEAS OF ASSOCIATES, LLC ) CUMBERLAND COUNTY ) Plaintiff ) vs. ) NO.: 11-310-CIVIL ) LAURA K AMSPACKER ) Civil Action ) Defendant ) ) SOVEREIGN BANK ) ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnis - SOVEREIGN BANK, dissolved. David J. Apothaker, Esquire Attorney for Plaintiff a o 461`51� Of-k Y94 Sic? 0-1-- (1)(1o(4, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ° aC.l }µ?e — t''e Chief Deputy Richard W Stewart i { t + Solicitor PEN.,S`( .''�' I. Portfolio Recovery Associates, LLC Case Number vs. Laura K.Amspacker 2011-310 SHERIFF'S RETURN OF SERVICE 07/11/2012 10:11 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 11, 2012 at 1005 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Laura K.Amspacker, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Denise Beecher,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 July 12, 2012 to Laura K. Amspacker at 23 S 39th Street, Camp Hill, PA 17011. 01/07/2014 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. Plaintiffs attorney was able to collect$ 759.12 from this garnishment. SHERIFF COST: $102.30 SO ANSWERS, January 07, 2014 RONNY R ANDERSON, SHERIFF aa� pI• 44 ��a� • WRIT OF EXECUTION and/or ATTACHMENT .•- COMMONWEALTH OF PENNSYLVANIA) NO 11-310 Civil COUNTY OF CUMBERLAND) CIVIL ACTION-LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC Plaintiff(s) From LAURA K.AMSPACKER,23 SOUTH 39TH STREET,CAMP HILL,PA 17011 (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: SOVEREIGN BANK,269 PENROSE PLACE,CARLISLE,PA 17013 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$3,600.00 L.L. $30 Interest FROM OCTOBER 21,2011 -$149.13 Atty's Comm % Due Prothy$2.25 Atty Paid $179.00 Other Costs$193.00 Plaintiff Paid WNW /,-0. I Daavvi. D. Buell,Prot onotary (Seal) / i._ • //_ Deputy REQUESTING PARTY: Name : DAVID J. APOTHAKER,ESQUIRE Address: APOTHAKER& ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 MOUNT LAUREL, NJ 08054 TRUE COPY FROM RECORD Attorney In Testimony whereof, I here unto set my hand y for: PLAINTIFF and the al of said Co rt at Carlisle, Pa. Telephone: 800-672-0215 This day of . U t 20 1W- Prothonota /� Supreme Court ID No.38423 +- ` L d SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson �� Sheriff ' xtit,, �t ar�a��a C Jody S Smith "'ik; 1F'it � '' Chief Deputy Richard W Stewart -- V+\11I. Solicitor �� 1, Portfolio Recovery Associates, LLC vs. Case Number Laura K.Amspacker 2011-310 SHERIFF'S RETURN OF SERVICE 01/09/2013 10:19 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on January 9, 2013 at 1019 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Laura K.Amspacker, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Julie Myers, Branch Operations 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. The writ of execution and notice to defendant was mailed on January 10, 2013 to Laura K.Amspacker at 23 S 39th Street, Camp Hill, PA 17011. 01/07/2014 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: $86.95 SO ANSWERS, January 07, 2014 RONNW ANDERSON, SHERIFF , sb w /11 as/ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-310 Civil COUNTY OF CUMBERLAND) CIVIL ACTION–LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PORTFOLIO RECOVERY ASSOCIATES,LLC, Plaintiff(s) From LAURA K. AMSPACKER,23 S 39th Street,Camp Hill,PA 17011 (I) 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: SOVEREIGN BANK,269 Penrose Place,Carlisle,PA 17013 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 $2,840.88 L.L. $ Interest from 10/21/11 --@228.06 Atty's Comm % Due Prothy 2.25 Atty Paid $222.00 Other Costs Plaintiff Paid David D. Buell,Prothonotary (Seal) B �l_ — • o!/. Deputy REQUESTING PARTY: Name : DAVID J. APOTHAKER,ESQURIE Address: APOTHAKER& ASSOCIATES,P.C. TRUE COPY FROM RECORD 520 FELLOWSHIP ROAD C306 In Testimony whereof,I here unto set my hand PO BOX 5496 and the seal of said • at Carlisle,Pa. This..a/ of •�= 20/a MOUNT LAUREL, NJ 08054 kviLe.de , Prothonotary Attorney for: PLAINTIFF Telephone: 800-672-0215 Supreme Court ID No.38423 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,,_i t [ Jody S Smith _$ } ° ' Chief Deputy ' ` E I ` ''rt; 1 Richard W Stewart s `t? , Solicitor ., � 'EIT4SJ'' LVAHlf!-. Portfolio Recovery Associates, LLC Case Number vs. 2011-310 Laura K. Amspacker SHERIFF'S RETURN OF SERVICE 06/21/2013 09:27 AM -Jamie DiMartle, Deputy Sheriff,who being duly sworn according to law, states that on June 21, 2013 at 0927 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Laura K.Amspacker, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania, by handing to Benjamin Stone, 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 him. The writ of execution and notice to defendant was mailed on June 25, 2013 to Laura K.Amspacker at 23 S 39th Street, Camp Hill, PA 17011. 01/07/2014 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: $87.75 SO ANSWERS, 4g, January 07, 2014 RONNY R ANDERSON, SHERIFF • '7 340 a-/,