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HomeMy WebLinkAbout11-3773THIS IS AN ASSESSMENT GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2102314 ARBITRATION MATTER. OF DAMAGES HEARING REQUIRED. LVNV FUNDING LLC COURT OF COMMON PLEAS 15 South Main Street, CUMBERLAND COUNTY Greenville, NC 29601 VS. DOCKET NO. ?VI, I Angela Shuler 222 Geary Ave NEW CUMBERLAND PA 17070-2037 F71 71 NOTICE- C YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINS7¢'c95HE?Z-LA S SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY= ),, AY j'dDFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARA? P RSO Lam' OR BY ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES OR OBM$CTIqN?0 THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO So CAE MAY PROCEED WITHOUT YOU AND A JUDGEMENT 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, 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 a avA %ga. ?, . 19 3 COMPLAINT IN CIVIL-ACTION 1. Plaintiff, LVNV FUNDING LLC a debt buyer and successor in interest to the original creditor, HSBC/Orchard Bank. 2. At all times relevant hereto, the defendant(s) was the holder of a credit card, which at the request of the defendant(s) was issued to the defendant(s) by the original creditor under the terms of which the original creditor agreed to extend to defendant(s)the use of original creditor's credit facilities. 3. Defendant(s) accepted and used the aforesaid credit card so issued and by so doing agreed to perform the terms and conditions prescribed by the original creditor for the use of said credit card. 4. The defendant(s)received and accepted goods and merchandise and/or accepted services or cash advances through the use of the credit card issued by the original creditor. A true and correct copy of the Statement of Account or Affidavit of Account, if available, is attached hereto as Exhibit "A". 5. All the credits to which the defendant(s)is entitled have been applied and there remains a balance due as of February 10, 2011 in the amount of $1,292.82. 6. Plaintiff has made demand upon the defendant(s)for payment of the balance due but the defendant(s)has failed and refused and still refuses to pay the same or any part thereof. 7. Defendant's last payment on account was made on 12/16/08. WHEREFORE, plaintiff claims of the defendant(s) the sum of $1,292.82 plus applicable costs, interest and attorney's fees. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEI BERG, ESQUIRE JOEL M. FL NK ESQUIRE Attorney f Plaintiff POIP.DB 2102314 VERIFICATION I, Scott Batson, hereby verify that: 1. I am employed by Resurgent Capital Services master servicer for LVNV Funding LLC with full authority to make this Verification on behalf of LVNV Funding LLC. LVNV Funding LLC is the successor in interest to HSBC/Orchard Bank. 2. For Account # 5407915001356390 I reviewed the following: ® Computerized Documents ? Hard Copy Documents; and F-I Other: Business System of Records 3. The foregoing account was opened on 11/14/2001 in the name of Angela Shuler . The documents that I reviewed were produced by HSBC/Orchard Bank, Standard - MCS. 4. Based on my review of the foregoing documents, at the time of the sale and assignment of the said account by HSBC/Orchard Bank, there was due and owing the purchased balance of $1,071.14 and counsel has incorporated the facts by reference in the foregoing Complaint in Civil Action. The language in the Complaint is that of counsel and not of Plaintiff so to the extent that the contents of the Complaint are that of counsel, Plaintiff has relied upon counsel in making this verification. 5. Based on my review of the foregoing documents, there are no payments that have not been credited and the debtor named in paragraph 3 above has not asserted any counterclaims or setoffs. 6. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unswom falsification to authorities in violation of 18 Pa. C.S. § 4904. Authorized Representative DATE: January 20, 2011 EXHIBIT "A" PLAINTIFF'S AFFIDAVIT OF INDEBTEDNESS AND OWNERSHIP OF ACCOUNT Now comes the undersigned affiant, who having first been duly sworn and cautioned according to law, depose and states as follows: 1. I am an Authorized Representative for LVNV Funding LLC (hereafter the "Plaintiff"). I am authorized to make this affidavit on its behalf, and the information below is true and correct to the best of my information and belief based on the Plaintiffs business records. 2. I have personal knowledge regarding Plaintiffs creation and maintenance of its normal business books and records, including computer records of its accounts receivables. This information was regularly and contemporaneously maintained during the course of the Plaintiffs business. 3. In the ordinary course of business, Plaintiff regularly acquires revolving credit accounts, installment accounts, service accounts and/or other credit lines. The records provided to Plaintiff have been represented to include information provided by the original creditor or its successors in interest. Such information includes the debtor's name, social security number, account balance, the identity of the original creditor and the account number. 4. To the best of my knowledge and belief, the Defendant is not a minor or mentally incompetent person. 5. Based upon the business records maintained on account 5407915001356390 (hereafter "Account"), which are a compilation of the information provided upon acquisition and information obtained since acquisition, the Account is the result of the extension of credit to Angela Shuler by HSBC/Orchard Bank on or about 11/14/2001 (the "Date of Origination"). Said business records further indicate that Account was then owned by IDT Carmel, Inc, that IDT Carmel, Inc later sold and/or assigned Portfolio 12546 to Plaintiff's assignor which included the Defendant's Account on 01/30/2009 (the "Date of Assignment") and on the Date of Assignment, all ownership rights were assigned to, transferred to, and became vested in Plaintiff, including the right to collect the purchased balance owing of $1,071.14 plus any additional accrued interest. I affirm under penalty of perjury that the above facts are true and correct. PA5k?) Nikki Foster January 22, 2011 The fo ego' g affidavit was signed to and subscribed before me this Saturday, January 22, 2011. (No Public) Maria Benedum Notary Public State of South C1 -4-20 My Comm. Exp• 2102314 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE 2102314 Identification No.: 41360 JOEL M. FLINK, ESQUIRE Cl) o -n C) Identification No.: 81894 -g3 -= 1001 E. Hector Street, Ste 220 zm rn--... Conshohocken, PA 19428 r N ?? 484/351-0500 d a .co z-n M CD = c? LVNV FUNDING LLC COURT OF COMMON PLEASAz ° ?m CUMBERLAND COUNTY --? VS. DOCKET NO. : 11-3773 CIVIL Angela Shuler PRAECIPE FOR ENTRY OF JUDGMENT FOR PANT OF AN ANSWZR ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and against defendant(s) above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $1,292.82 Less: Payments on Account ( $.00) Total: $1,292.82 Understanding the false statements made herein are subject to penalty under 18 Pa.C.S.A. §4904, Unsworn Falsification to Authorities, I verify that: 1. The last known addresses of the parties are: LVNV FUNDING LLC and that the last known address of defendant, Angela Shuler, 222 Geary Ave, NEW CUMBERLAND PA 17070-2037. 2. The annexed notice(s) of intention to file this praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ten days prior to the date of filing of this praecipe. 3. The said defendant(s) is (are) service of the United States or otherwise the Soldiers and Sailors Civil Relief Act years of age. not in the military within the coverage of and is (are) over 18 ami %1q. co pd a fk. ctcg ? P- &o- 1? Y. &ha (Ula?.led AND NOW, this Do day of ?(J-11 (E , 2011 Judgment is entered in favor of the plaintiff(s) and against defendant(s) by default for want of an answer d d ages assessed at he sum of $1,292.82 as per the above cert' icat n. Pro GORDON & WEINB G, P.C BY: FREDERIC I. WE BERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff 2102314 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV FUNDING LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. Angela Shuler 222 Geary Ave NEW CUMBERLAND PA 17070-2037 DOCKET NO. : 11-3773 CIVIL NOTICE Pursuant to Pa.R.Civ.P. 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. (XL Judgment by Default $1,292.82 Money Judgment $ Judgment on Award of Arbitrators$ L_L Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I. WEINBERG OR J EL M. FLINK, ESQUIRES THIS TELEPHONE NUMBER: 484/351-0500 PROT RY GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2102314 LVNV FUNDING LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Vs. DOCKET NO. : 11-3773 CIVIL Angela Shuler NOTICE OF INTENTION TO TAKE DEFAULT TO/PARA Angela Shuler 222 Geary Ave NEW CUMBERLAND PA 17070-2037 DATE OF NOTICE/FECHA DEL AVISO: May 24, 2011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AN 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 BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: V FREDERIC I.;`WEINBERG, ESQUIRE JOEL M. FLL4K, ESQUIRE P10D-2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-3773 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING LLC, Plaintiff (s) From ANGELA SHULER, 222 GEARY AVENUE, NEW CUMBERLAND, PA 17070-2037 (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: MEMBERS 1sT FCU, 401 EAST KING STREET, SHIPPENSBURG, PA 17257 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 $1,292.82 Interest FROM JUNE 20, 2011 - $82.25 L.L. $.50 Atty's Comm % Atty Paid $182.50 Plaintiff Paid Date: 7/19/12 (Seal) REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG P.C. Due Prothy $2.25 Other Costs David D. Buell, Prothonotary 'B-?C ?? Deputy 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 2102314 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 F iLEO-OFFIC; O THE PROTHONOTAK-i' 2012 JUL 19 PM 2: 03 OO PEN SY VANIA TY LVNV FUNDING LLC 15 South Main Street Greenville, NC 29601 VS. Angela Shuler 222 Geary Ave NEW CUMBERLAND PA 17070-2037 and Members lst FCU 401 East King St Shippensburg, PA 17257 GARNISHEE TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-3773 CIVIL PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against Angela Shuler (2) against Members 1st FCU (3) AMOUNT DUE INTEREST from June 20, 2011 COSTS defendant(s)and garnishee(s) $1,292.82 $82.25 Prothonotary fee Sheriff fee (4) Less: Payments on Account ( $.00) DLOI , ' a c{5 .oo CBF 9a.W«u (4, DG S> TOTAL S ZZ--6 FREDERIC I. WEINBERG, ESQUIRE 461)V C JOEL M. FLINK, ESQUIRE SDw Attorney for Plaintiff I 8N i ?0 ,? 278iN SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 1, ? a l P LVNV Funding, LLC vs. Angela Shuler Case Number 2011-3773 SHERIFF'S RETURN OF SERVICE: 07/30/2012 11:11 AM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on Julys 30, 2012 at 1111 hours, attached as herein commanded all goods, chattels, rights, debts, credits. and monies of the within named defendant, to wit: Angela Shuler, in the hands, possession, or control of the within' named garnishee, Members 1 st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Jaen Finkle, Member Service Representative, 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 31, 2012 to Angela Shuler at 222 Geary Avenue, New Cumberland, PA 17070-2037. SO ANSWERS, July 31, 2012 RbNN R ANDERSON, SHERIFF Elizabeth Muller, Deputy GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC 15 South Main Street Greenville, NC 29601 VS. Angela Shuler 222 Geary Ave NEW CUMBERLAND PA 17070-2037 and Members 1st FCU 401 East King St Shippensburg, PA 17257 GARNISHEE AUG t DOCKET NO. 11-3773 CITL,.3 MW :00 r-' -> N ::C? ?w A ? INTERROGATORIES tATTACHMENT TO: Members 1st FCU - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so result in judgment against you. 1 2012 ;.. -,... •.o; CD 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 the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 0c) 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in whic defendant held or claimed any interest. OD 4. At the time you were served or at any subsequent tim did you hold as fiduciary any property in which the defendant(s) had an interest? 00 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 direAfi(04 or consent and if so what was the consideration therefore? Q o 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 his(her, their) direction or otherwise discharge an claim of the defendant(s) against you? Q p 7. If you are a bank or other financial institution, a the time you were served or at any subsequent time, did the defendant(s) have funds on deposit in an account in which funds are deposited electronically a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal la If so, identify each account and state the reason f the exemption, the amount of funds in each account, the amount being withheld under each exemption and entity electronically depositing those funds on a recurring basis. Q O 8. If you are a bank or other financial institution, at the time you were served or any subsequent time dic 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 monetary exemption under 42 Pa.C.S. §812 If so, identify each account. ?ZS -?.?w?w. 0•\.1 S\? 9. How much is the value of any property in your possession belonging to the defendant(s)? * 119.`1Y FREDERIC I. W I ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff DATED:?I? 2012 e {IY?hEI? Sl9iiz -KCA a GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE AUG 1 2012 Identification No.: 41360 JOEL M. FLINK, ESQUIRE .....a Identification No.: 41200 1001 E. Hector Street, Ste 220 rrtUD Conshohocken, PA 19428 484/351-0500 - , A ? r LVNV FUNDING LLC COURT OF COMMON PLEASpC- , v?--; 15 South Main Street CUMBERLAND COUNTY . ?' - Greenville, NC 29601 ^ VS. DOCKET NO. 11-3773 CI L Angela Shuler C- 222 Geary Ave NEW CUMBERLAND PA 17070-2037 and .r , Members lst FCU 401 East King St Shippensburg, PA 17257 ? m??? GARNISHEE ' 40 INTERROGATORIES IN ATTACHMENT TO: Members 1st FCU - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so result in judgment against you. 1. At the time you were served or at any subsequent tin did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to t defendant for any reason? 2. At the time you were served or at any subsequent tine was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. PC) 3. At the time you were served or at any subsequent tine did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest. OZ) 4. At the time you were served or at any subsequent ti did you hold as fiduciary any property in which the defendant(s) had an interest? 00 5. At any time before or after you were served did the defendant(s) transfer or deliver any property to yo t or to any person or place pursuant to your direp or consent and if so what was the consideration therefore? Q0 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 his(her, their) direction or otherwise discharge an claim of the defendant(s) against you? Q 7. If you are a bank or other financial institution, a the time you were served or at any subsequent time, did the defendant(s) have funds on deposit in an account in which funds are deposited electronically a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal la If so, identify each account and state the reason f the exemption, the amount of funds in each account, the amount being withheld under each exemption and entity electronically depositing those funds on a recurring basis. ?j 0 8. 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 the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. §812 F 9. If so, identify each account. ?-Cs o.?ya ,\c How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC I. W I ERG, ESQUIRE JOEL M. FLINK, ESQUIRE /( / Attorney for Plaintiff DATED: l!( iZ Arnenc? d - c??SC?S F?f 8' ? 8/q ? ? 12 q. qg jb-fa.l I nclud, n? ?eL41 M 1 s' FC u 2012 n e •R ? e y?1?o n. , fxe e ~ , ~. __ 8~ 2102314 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 LVNV FUNDING LLC vs. Angela Shuler and Members 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY C"] ra ~C _ 3 N ~~ N -< ~ O <~ ~ -v .rte.., ~1 "rj, C„ GJ --y C. ,? DOCKET N0. 11-3773 CIVIL NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU AR HEREBY NOTIFIED THAT A JUDGMENT UPON ADMISSIONS HAS BEEN ENTE AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE FREDERIC I. WEINBERG, ESQUIRE AT 484/351-0500 ~.~::J~ ~-, :i} .... f „%..~ rn __.: ~r-r' t.7 -~ a c~x ~~ f"') .~,i ~'"t ~;~.{ .r. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 2102314 LVNV FUNDING LLC 15 South Main Street Greenville, NC 29601 vs. Angela Shuler and Members 1st FCU Garnishee -< COURT OF COMMON PLEAS .'~~~~' CUMBERLAND COUNTY ~ y, .~W DOCKET N0. 11-3773 CIVIL PRAECIPE FOR JUDC~NT UPON ADMI33ION TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, LVNV FUNDING LL ~ i,aQa.sa and against the Garnishee, Members 1st FCU, in the amount of :b~l admitted in the Answer to Interrogatories to be in the Garnishee' possession, together with interest and costs which is not more than th amount of the judgment of the Plaintiff against the Defendant togethe with post judgment costs and post judgment interest which is $~3~4-~,~53 # ~,a9a. 8a Date: ~ ~~ GORDON & WEINBERG, P.C. BY: FREDERIC I.~BERG, ESQUIRE JOEL M. FLI , ESQUIRE Attorney for Plaintiff c x(033 ~ a~~ ~~~ --t -n t-rr ~~ ~-~ , ~~ ~ -+ ~~ r I- '~~yyC2 A t'N ~``~' q GORDON & WEINBERG, P . C. ~ ~ n ~ 2~~ BY: FREDERIC I. WEINBERG, ESQUIRE U J Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 c`'-~„ 1001 E. Hector Street, Ste 220 ~~ s Conshohocken, PA 19428 zn~t c 484/351-0500 ~~ _~ - --_ __ ___ ,may. c~ - LVNV FUNDING.LLC COURT OF COMMON PLEAS<~ 15 South Main Street CUMBERLAND COUNTY ~~ Greenville, NC 29601 ~~ w .. ..., ~ ` •-~~ c A [ ) -F~.,S vs. DOCKET NO. 11-3773 CI'~ L ~' ~~ N 7s Angela Shuler ~ ~ 222 Geary Ave ~~ ~ NEW CUMBERLAND PA 17070-2037 ~~ N C o a~ ~ and ~. ~ ~'*? Members 1st FCU ~ -- 401 E t Kin St '`~ '~ as g Shippensburg, PA 17257 GARNISHEE ~1~~ ~ INTERROGATORIES IN ATTAC~iT TO: Ma+mbars 1st FCU - GARNISHEE You are required to file answers to the following Interrogatories within twenty (20) days after service upon you. Failure to do so result in judgment against you. Auc~ 1 2012 '~~~~ ~-` s= ~_. r-•.., f_.) ~ ~ --~ ~_, a:>> ^~•, ~:~ ~;_ ': a _~.`i --s r~*t r= r~ .~ c --~ ~ ~ '"ri c:~ -~-; --- ca ::; ~~~ -.r" 1. At the time you were served or at any subsequent t' e did you owe the defendant(s) any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim tha you owed the defendant any money or were liable to the defendant for any reason? ~.~~ 2. At the time you were served or at any subsequent t' e was there in your possession, custody or control o in the joint possession, custody or control of yourse f and one or more other persons any property of any nature owned solely or in part by the .defendant. N 3. At the time you were served or at any subsequent t'me did you hold legal title to any property of any na ure owned solely or in part by the defendant or in which defendant held or claimed any interest. N ~ 4. At the time you were served or at any subsequent t did you hold as fiduciary any property in which th defendant(s) had an interest? ~~ 5. At any time before or after you were served did th defendant{s) transfer or deliver any property to y ~~~r~.~U RECEIVED a -'• or to any person or place pursuant to your dire(pi 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 his(her, their) direction or otherwise discharge and claim of the defendant(s) against you? ~ p 7. If you are a bank or other financial institution, ai the time you were served or at any subsequent time, did the defendant(s) have funds on deposit in an account in which funds are deposited electronically a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal lay If so, identify each account and state the reason f~ the exemption, the amount of funds in each account, the amount being withheld under each exemption and 1 entity electronically depositing those funds on a recurring basis. ~ ~ 8. If you are a bank or other financial institution, ai the time you were served or any subsequent time dic 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 o the general monetary exemption under 42 Pa.C.S. §81; .~--If so, identify each account. ~~s -'"$u.\w.~ d.\~..(a i\~ ~~\„~s ~< 9. How much is the value of any property in your possession belonging to the defendant (s} ? fit' ~ 1°}.`l~' DATED: ~,~~~ FREDERIC I. W I ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff ~rnenc~ d - c~~sd-s ~ 2,12 y. q~S ~a,l ~~.~ MI~FCu £~~8' d~ 8"/9 ~ ~nclud~n8 on r zotz '. 3 ? ~.R g ~~~ a 2102314 CORDON & WEINBERG, F.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FUNK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 c-~ C "L7! 3 cn -<~°" ~~ --C r• ~' ~~a t z to -,.i LVNV FUNDING LLC vs. Angela Shuler and Members lst FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET N0. 11-3773 CIVIL ORDER TO SATISFY JtJDGi~NT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly mark the judgment entered against garnishee Members 1st FCU in the above-captioned matter satisfied upon payment of your costs only. P013 CORDON & WEINBERG, P.C. BY: FREDERIC IINBERG, ESQUIRE JOEL M. FUNK, ESQUIRE Attorney for Plaintiff `~~t a- --,(mss ra r~ ~~ ft;,x ._.~ -~4.so Pa rN ~~' I880 ~~o~ ~ ~.