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HomeMy WebLinkAbout11-4875LVNV FUNDING LLC In the Court of Common Pleas of c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania n , 120 North Keyser Ave. Civil Division ° Scranton, PA 18504 mca --0:M c_ -? t Plaintiff M C= ..,O m NO: / UU -? o -? o VS. ?Cj- TJr r 7"x"1 Mark Coxen PRAECIPE FOR ENTRY OF JUDGME Nt E5 j= 114 NOVEMBER DR APT 1 " CAMP HILL PA 17011 Defendant To the Prothonotary of CUMBERLAND County: 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: February 1, 2011 B) Amount of Judgment: $1,350.41 C) Interest From: February 1, 2011 2) Enter the judgment in favor or the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3) I hereby certify that the address of the plaintiff is: LVNV FUNDING LLC c/o Edwin A. Abrahamsen & Assoc. 120 North Keyser Ave. Scranton, PA 18504 4) I hereby certify that the address of the defendant is: Mark Coxen 114 NOVEMBER DR APT 1 CAMP HILL PA 17011 Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. 120 N. Keyser Ave Scranton, PA 18504 570-558-5510 Ext. 101 Attorney ID 86285 /1/fi lie ??c`( COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-1-02 MDJ Name: Honorable Barbara A. Clare Address: 1901 State Street Camp Hill, PA 17011 Telephone: 717-761-0583 Michael Ratchford, Esq. 120 N Keyser Ave c/o Edwin A Abrahamsen & Associates PC Scranton, PA 18504 Disposition Summary Docket No MJ-09102-CV-0000502-2010 Judgment Summary Participant Mark Coxen $0.00 $1,350.41 Amount $1,350.41 Judgment Detail (*Post Judgment) In the matter of LVNV Funding LLC vs. Mark Coxen on 2/01/2011 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,254.91 $1,254.91 Filing Fees $0.00 $95.50 $95.50 Grand Total: $1,350.41 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. f EB 0 1 2011 I certify that this is a true and correct proceedings JA/) Judge Barlrara A. Clare MDJS 315 Page 1 of 1 Printed: 02/01/2011 10:51:17AM 1`K25 Plaintiff Defendant LVNV Funding LLC Mark Coxen Joint/Several Liability Individual Liability 01_lawel? rl C'rn,7, Date Magisterial District Judge Barbara A. Clare;. LVNV Funding LLC V. Mark Coxen Docket No: MJ-09102-CVr,D000W2-2R0 Case Filed: 12/9/2010 `133 -- "+ r'Tt rri C= '"71 r-= c:7 C:? -r b x' ?Z Disposition Disposition Date Default Judgment for Plaintiff 02/01/2011 LVNV FUNDING LLC c/o Edwin A. Abrahamsen & Assoc. 120 North Keyser Ave. Scranton, PA 18504 Plaintiff VS. Mark Coxen 114 NOVEMBER DR APT 1 CAMP HILL PA 17011 Defendant In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): Mark Coxen is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): Mark Coxen is(are) older than eighteen years of age; That the employment status of the defendant(s): Mark Coxen is(are) unknown. Subscribed before me this- day of. 146tary Public SCE t`.IT';t? J?'!1G-"'ITY AH?l.2"i14 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jun-02-2011 10:10:36 44, Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency COXEN MARK Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Ohl Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtair further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 6/2/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service rzember who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:2V2RB15258 https://www.dmdc.osd.mil/appj/scra/popreport.do 6/2/2011 LVNV FUNDING LLC In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff ' vs. : NO: Mark Coxen 114 NOVEMBER DR APT 1 NOTICE OF FILING JUDGMENT CAMP HILL PA 17011 Defendant : Notice is herby given that a money judgment in the above-captioned matter has been entered against you in the amount of $ J , 3 5-o, y/ on /6 zd// e,MIZ W.- - If you have any questions regarding this notice, please contact the filing parry: Edwin A. Abrahamsen & Associates 120 N. Keyser Avenue Scranton, PA 18504 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) 2183633 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 zuRomr -2 Ff1 1: 4 l CUNB ERL A ND COO LVNV FUNDING LLC vs. Mark Coxen COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4875 CIVIL ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above -captioned matter. GORDON & WEINBERG, P.C. BY: P012 FREDERIC/ ! WEINBERG, ESQUIRE JOEL M./LINK, ESQUIRE Attorney for Plaintiff CERTIFICATION OF SERVICE I, JOEL M. FLINK, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre -paid, to all other parties or their counsel of record. Dated: 1 � JOEL mioifK, ESQUI' 2183633 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 2014 PENNS Y+ t�A UNT \r LVNV FUNDING LLC 625 Pilot Road, Suite 3 Las Vegas, NV 89119 vs. =Mark Coxen ggg114 November Dr Apt 3 —Camp Hill PA 17011-5040 and ---M&T Bank =1 West High Street Carlisle, PA 17013 GARNISHEE TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4875 CIVIL PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (1) against Mark Coxen (2) against M&T Bank defendant(s)and garnishee(s) (3) Amount Due Interest from June 10, 2011 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL soak sack, a am as cgs as a -s -P" 44,5) "'FREDERIC I n JOEL M. L Ct IAttorney FfA4 ItIsLi S3 $1,350.41 $236.19 $.00 BERG, ESQUIRE , ESQUIRE Plaintiff THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net LVNV FUNDING LLC Vs. MARK COXEN WRIT OF EXECUTION (Pa R.C.P. 3252) NO 11-4875 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against MARK COXEN, 114 NOVEMBER DR. APT 3, CAMP HILL, PA 17011 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of M&T BANKGARNISHEE(S), as garnishee, 1 WEST HIGH STREET, CARLISLE, PA 17013 (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $1,350.41 Interest FROM JUNE 19 2011 - $236.19 Attorney's Comm. % Attorney Paid $56.25 Date: 5/27/14 (Seal) Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. Buell, Prothonotary REQUESTING PARTY: Name : JOEL M. FUNK, ESQUIRE Address: GORDON & WEINBERG, P.C. 1001 E. HECTOR STREET, SUITE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41200 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW I. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY ;; HE Jr 0THONJ T °:': ayfttr Ua cunar. 2ft111 JUN -6 Mi {0+; 5 # Richard W Stewart "' r "" CUMBERLAND COUNTY Solicitor PENNSYLVANIA, OPF CE OF THE E4iERIFF. LVNV Funding LLC vs. Case Number Mark D. Coxen 2011-4875 SHERIFF'S RETURN OF SERVICE 06/02/2014 01:18 PM - Dennis Fry, 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, 960 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Lisa Thomas, 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 June 4, 2014 to Mark Coxen at 114 November Drive, Apt. 3, Camp Hill, PA 17011-5040. June 04, 2014 (c) CountySuite Sheriff, Teleosoft, nc. DEN FRY, DETY SO ANSWERS, RON;?-R ANDERSON, SHERIFF GORDON & WEINBERG, P.C. BY: c ''REnERIC 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 625 Pilot Road, Suite 3 Las Vegas, NV 89119 vs. Mark Coxen 114 November Dr Apt 3 Camp Hill PA 17011-5040 and M&T Bank 1 West High Street Carlisle, PA 17013 GARNISHEE ' r�C rHOAtio A ' 2814 JUN 30 PFf I; 55 CUNBERL An, COURT OF COMMON PLEAS NMS Y1.414P1 TY CUMBERLAND COUNTY DOCKET NO. : 11-4875 CIVIL ansvex3 rb INTERROGATORIES IN ATTACHMENT 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 my 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 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 de dant for any reason? HAS No O4 TBANK EN acc, 2. At the time you were served or at any sul ' Ai.rCM �s there in your possession, custody or control or in the j4 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. 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 which defendant held or claimed any interest. ij' 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 an interest? 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 if so what was the consideration therefore? P 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 any claim of the defendant(s) against you? 7. 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 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, the amount of funds in each account, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. 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. §8123? If so, idenAWy each account. 9. How much is the value of any property in your possession belonging to the defendant(s)? FREDERIC I. W JOEL M. FLIN Attorney for DATED: S 11111 JUN 2 5 2014 CATHY S FISHER M&T BANK RG, ESQUIRE ESQUIRE laintiff 2183633 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 r/! - �%� THEfiCi - o J` i 7©/�,JUL _ 1 Qtd©T PMpeNNS k",4 N4,1 ly 3: �� LVNV FUNDING LLC Mark Coxen and M&T Bank vs. Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-4875 CIVIL PRAECIPE TO DISSOLVE ATTACHMENT TO THE PROTHONOTARY: Kindly dissolve the attachment against M&T Bank, as Garnishee in the above entitled matter. GORDON & WEINBERG, P.C. BY: P011 FREDERIC I. BERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff QJ\k- ?t y