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Home My WebLink About11-6210LVNV FUNDING LLC P.O. Box 10584 Greenville, SC 29603 vs. Peggy Oakes 50 BONNYBROOK RD LOT 9 CARLISLE PA 17013-4208 Metro Bank 65 Ashland Ave Carlisle, Pa 17013 Defendant vs. Garnishee NO: 11-6210 CIVIL : r C ) Z o Z- Praecipe for Entry of Appearance Kindly enter my appearance on behalf of LVNV FUNDING LLC in the above-captioned matter. Date: February 23, 2012 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Plaintiff Civil Division Telephone No: 570 5 Supreme Court ID No: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6210 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING LLC Plaintiff (s) From PEGGY OAKES, 50 BONNYBROOK ROAD, LOT 9, CARLISLE, PA 17013-4208 (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: METRO BANK, 65 ASHLAND AVENUE, CARLISLE, PA 17013 ANY AND ALL ACCOUNTS OF THE DEFENDANT(S), IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATES OF DEPOSIT; MONEY MARKET ACCOUNTS; CONTENTS OF SAFETY DEPOSIT BOXES. 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 hinvher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,164.30 Interest $71.87 Atty's Comm % Atty Paid $58.75 Plaintiff Paid Date: 3/19/12 (Seal) L.L. $.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name MICHAEL F. RATCHFORD, ESQUIRE Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: Plaintiff Telephone: 570-558-5510 EXT 101 Supreme Court ID No. 86285 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a) LVNV FUNDING LLC P.O. Box 10584 In the Court of Common Pleas of Greenville, SC 29603 CUMBERLAND County, Pennsylvania Plaintiff Civil Division - -71 . vs. A 6 -< .. r r . Peggy Oakes NO: I1-6210 CIVIL -? . 50 BONNYBROOK RD LOT 9 ? CD CARLISLE PA 17013-4208 Defendant : PRAECIPE FOR WRIT OF EXECUTION Alm vs. ATTACHMENT Metro Bank 65 Ashland Ave Carlisle, Pa 17013 (MONEY JUDGMENT) Garnishee To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania; (2) Against: Peggy Oakes a (3) And against: Metro Bank 65 Ashland Ave Carlisle, Pa 17013 f-..5 CD (4) and index this writ (a) against m ?r- .,cj Defendant(s) (b) against Metro Bank 65 Ashland Ave Carlisle, Pa 17013 Garnishee - CD as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s), any and all accoy;t?f tIS CZ) defendant(s), in the possession of Garnishee, including but not limited to savings account balances; checkingalcco?+tR balances; Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes. Defendant's ESN(s):` 455-57-1558; (5) Judgment Amount $2.164.30 Interest 71.87 Clerks Fee $ Sheriff $ Poundage $ Total $ /I .4 Date: February 23, 2012 ?C" a. so « F4id'hae F/Ratch'ford, Esquire Edwin . Abrahamsen & Associates, Attorney for Plaintiff mratchford@eaa-law.com ja . Sa ?? 171v gwsty? I A J, -? 01 ?2y --t-:ssqd SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor MA, 2 7 pp j 2; 4 PENN 'la?l. ,. LVNV Funding, LLC Case Number vs. 2011-6210 Peggy Oakes SHERIFF'S RETURN OF SERVICE 03/23/2012 10:12 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2012 at 1012 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Peggy Oakes, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Carol Walters, Customer 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 March 26, 2012 to Peggy Oakes at 50 Bonnybrook Rd, Lot 9, Carlisle, PA 17013. SO ANSWERS, March 26, 2012 RON R ANDERSON, SHERIFF W iam line, Deputy LVNV FUNDING LLC P.O. Box 10584 Greenville, SC 29603 vs. Peggy Oakes 50 BONNYBROOK RD LOT 9 CARLISLE PA 17013-4208 vs. Metro Bank: 65 Ashland Ave Carlisle, Pa 17013 Plaintiff Defendant Garnishee In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: 11-6210 CIVIL ") kTO ? 7 I NTERRO ES IN ATTACHMENT c•? RE: Execution of Judgment against your depositor Peggy Oakes SSN # 455-57-1558 You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in judgment against you: 1) At the time you were served or at any subseqent time, did the Defendant possess any bank accounts, joint or individual, that were in your custody or control? Please specify joint or individual account. Please list the legal title of any such account(s) an dthe primary account holder and if known whether joint account is entireties property. Defendant receives unemployment Compensation. 2) At the time you were served or at any subsequent time, what was the balance and account number of the bank accounts(s) identified in Interrogatory # 1? 3) At the time you were served or at any subsequent time, please list the average daily balance in the past five (5) months for each such account identified in your answer to Interrogatories number one (1) and two (2) above. 4) At the time you were served or at any subsequent time, did the bank account(s) that the Defendant possessed contain fund derived solely from social security funds and/or disability funds? 5) At any time before or after you were served, did the Defendant(s) transfer or deliver any property or money to you or to any person or place pursuant to your direction or consent, and if so, what was the consideration therefore? 6) At any time after you were served, did you pay, transfer or deliver any money or property to the Defendant(s) or to any person or place pursuant to the Depositor's direction or otherwise discharge any claim of the Depositor against you? 7) At the time you were served or any subsequent time, did you have, share, or utilize any safe-deposit boxes, pledges, documents of title, securities, notes, coupons, receivable, license, or collateral in which there was an interest claimed by Defendant(s)? 8) At the time you were served or at any subsequent time did the Defendant(s)account contain funds deposited electronically on a recurring basis and which are identified as being exempt from execution, levy or attachment. If so, state the reason for the exemption, the amount being withheld and the entity electronically depositing those funds on a recurring basis. 9) At the time you were served or at any subsequent time did the defendant 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. Section 8123? If so, identify each account. 10) Identify every other account (not previously noted) titled in the name of the Defendant(s) in which you believe the Defendant(s) have an interest in whole of part, whether or not styled as a payroll account, individual retirement account, tax account, lottery account, partnership account, joint or tenants by entirety account, insurance account, trust or escrow account, attorney's account, or otherwise. 11) To the extent that you're above answers depend in whole or part on documents, account records, or other papers or electronic data, describe each in exact detail (or attach a copy of the same). Edwin A. AbrkamsenA A lion l F. Ratchford, Esqu 2 North Keyser Avenue Scranton, PA 18504 (570) 558-5510 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating to unsworn falsifications to authorities, that he/she is Jennifer Hilbish (Name) Levy Specialist _ of Metro Bank, garnishee herein, (Title) (Company) that he/she duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. L ( LVNV FUNDING LLC GATEWAY Plaintiff vs. Peggy Oakes 50 BONNYBROOK RD LOT 9 CARLISLE PA 17013-4208 Defendant Metro Bank 65 Ashland Ave Carlisle, Pa 17013 vs. Garnishee . In the Court of Common Pleas of CUMBERLAND County Pennsylviw = , Civil Division "? ` ??'" ?J m,.n 4Tl T NO: 11 -62 10 CIVIL C:? _ ( Praecipe to Dissolve the Attachment against Garnishee To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, Michael F. Ratchfo Edwin A. Abraham Lawyer ID # 86285 & Associates, P.C. Sworn and subscribed before me on this -- day of 20_La= Notary Public COMM_? F PENNSYLVANIA Dana L. 5 ? ? pubk aty of scrawm, wAa+??aoea capty C.DMMISWM ?S J* 22015 MEMBER, PENNSYLVANU AMM q 010 -% q.Sopd 04,4 Z4!59),( p-4?- 6? 7 9 -7 (06 ,~ __ SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,< Anderson ~li ~.-~iti1 ~`at°t~f. °~ i ~~~ PPQTH~?Nt~~ ~~,;-~',' ,dy S Smith chief Deputy Richard W Stewart Solicitor 2~ 12 IVOU - i PM ~- 17 ~t.~~t~~~~~~~ i;t7J~dT~' P~~I~SYLI~ANIp LVNV Funding, LLC vs. Peggy Oakes SHERIFF'S RETURN OF SERVICE Case Number 2011-6210 03/23/2012 10:12 AM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2012 at 1012 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Peggy Oakes, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Carol Walters, Customer 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 March 26, 2012 to Peggy Oakes at 50 Bonnybrook Rd, Lot 9, Carlisle, PA 17013. 10/29/2012 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: $88.84 SO ANSWERS, ~~ October 29, 2012 RON .~ R ANDERSON, SHERIFF •sv ~,~~ • ~-~' ~ ~~" ,~ ~ ~~ s~7