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HomeMy WebLinkAbout11-8981 Our File No.: 317399 LVNV FUNDING, LLC IN THE COURT OF COMMON PLEAS OF Plaintiff L CUMBERLAND COUNTY, PENNSYLVANIA vs. VANESSA MOORE A/K/A PRICE NO.: 2011-8981 CIVIL TERM Defendant(s) Lq ' �� �i�G(,e �� , ?P I )b PRAECIPE FOR WRIT OF EXECUTION ' '` To the Prothonotary: a Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; ` co (2) against VANESSA MOORE A/K/A PRICE, defendant(s); and x (3) against ORRSTOWN BANK 1 GIANT LANE CARLISLE, PA 17013 and METRO B 1K�;5 ASHLAND AVE CARLISLE, PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against VANESSA MOORE A/K/A PRICE, defendant(s), and (b) against ORRSTOWN BANK 1 GIANT LANE CARLISLE,PA 17013 and and METRO BANK 65 ASHLAND AVE CARLISLE, PA 17013, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s)as follows: Bank Attachment Only - All assets and accounts including but not limited to bank accounts brokerage firm accounts, stocks, cd's insurance safety deposit boxes etc (5) Amount Due $1213.76 Interest from September 19, 2011 $107.95 Minus Payments made $0 Plus Costs $206.25 Total $1527.96 09(q h 0 o� oC S OF David J. Apothaker, Esq. d S4 aS a `35 'PWy fir Plaintiff(s) �-C� Lt CIL# `7101 6 5T 99?1 1 )ri � 4(_v 2 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-8981 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due LVNV FUNDING,LLC Plaintiff(s) From VANESSA MOORE A/K/A PRICE,418 RAYSTOWN CIRCLE,SHIPPENSBURG, PA 17057 (1) You are directed to levy upon the property of the defendant(s)and to sell (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: ORRSTOWN BANK, 1 GIANT LANE,CARLISLE,PA 17013 METRO BANK,65 ASHLAND AVENUE,CARLISLE,PA 17013-ALL ASSETS AND ACCOUNTS,INCLUDING BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof, (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$ 1,213.76 Plaintiff Paid$ Interest FROM SEPTEMBER 19,2011 -$107.95 Attorney's Comm. % Law Library$.50 Attorney Paid$$56.25 Due Prothonotary$2.25 Other Costs$206.25 Date: 3/28/13 � r David D. Buell,Prothonotary By: Deputy REQUESTING PARTY: Name : DAVID J.APOTHAKER,ESQUIRE Address: APOTHAKER&ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 P.O.BOX 5496 MOUNT LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 856-780-1000 Supreme Court ID No. Our File No.: 317399 LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF Plaintiff ) CUMBERLAND COUNTY VS. ) VANESSA MOORE A/K/A PRICE ) INTO.: 2011-8981 CIVIL TERM 418 RAYSTOWN CIR ) SHIPPENSBURG, PA 17257 ) Civil Action XXX-XX-6814 ) c.D Defendant ) c ire- "o-" ORRSTOWN BANK and METRO BANK ) mac" N) Garnishee =CD CD S 5c INTERROGATORIES TO GARNISHEE -% TO: ORRSTOWN 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? Defendant Vanessa Moore does no have accounts.with Metro Bank. Vanessa Price has account with less than $300 exemption 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)? 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? 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? 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? 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? 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. 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. 9. How much is the value of any property in your possession belonging to the defendant(s)? 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: David J. Apothaker,Esquire APOTHAKER&ASSOCIATES,P.C. 520 Fellowship Road C306 PO Box 5496 Mount Laurel,New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff 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 pecialist 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. , SIG E) 6 r . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F1LED-0F'FtCE Sheriff 14 E P `()t,H0 �����y,X91 � Jody S Smith ? 3 PIA iv 3 1 , f1 10: Chief Deputy �' Richard W Stewart `=`° CUMBERLAND Solicitor r a T , t l - P OSY Y C0U LVNV Funding, LLC Case Number vs. Vanessa Moore 2011-8981 SHERIFF'S RETURN OF SERVICE 04/08/2013 01:37 PM-William Cline, 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, Orrstown Bank, 22 South Hanover Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Kristin Ramsay,Assistant 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 her. 04/08/2013 01:43 PM -William Cline, 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, Metro Bank, 20 Noble Boulevard., Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Audrey Bistline, Customer Service Rep., 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 April 8, 2013 to Vanessa Moore at 418 Raystown Circle, Shippensburg, PA 17257. 05/30/2013 Received copy of Praecipe to Dissolve Attachment Execution against the Garnishee, Metro Bank, and against Garnishee Orrstown Bank. 05/30/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. SHERIFF COST: $144.50 SO ANSWERS, May 30, 2013 RbNW R ANDERSON, SHERIFF 4#7 {c}CountySuite Sheriff,Teleosoft,InC. M .' Our File No.: 317399 -0 APOTHAKER&ASSOCIATES, P.C. _ C i ry By: David J. Apothaker,Esquire ' 520 Fellowship Road C306 ' C3 PO Box 5496 : Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 2011-8981 CIVIL TERM VANESSA MOORE A/K/A PRICE ) Civil Action Defendant ) ORRSTOWN BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, TOWN BANK, dissolved. David J. Apothaker,Esquire Attorney for Plaintiff 0.50 PA ATT-y 0-1 Mo C 0 -hz Cz Our File No.: 317399 "- APOTHAKER&ASSOCIATES,P.C. i ; By: David J. Apothaker,Esquire ' a gym; 520 Fellowship Road C306 -0 - PO Box 5496 r CD ti 1 Mount Laurel,NJ 08054 Pi (800) 672-0215 - ' Attorneys for Plaintiff LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 2011-8981 CIVIL TERM VANESSA MOORE A/K/A PRICE ) Civil Action Defendant ) METRO BANK ) Garnishee ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee ME RO BANK, dissolved. Dav othaker,Esquire Attorney for Plaintiff 44.50 Pb A e f79gq I Or IS �"li t- Our File No.: 317399 1; F - APOTHAKER& ASSOCIATES, P.C. `-- PRO BY: David J. Apothaker, Esquire 2013 JUN / Attorney I.D.# 38423 N//: 0 520 Fellowship Road Mount Laurel, 06 NJ 0 054 PE Q} ' Cp,JNT V (800) 672-0215 LVAN/A Attorney for Plaintiff LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) vs. ) VANESSA MOORE A/K/A PRICE ) NO. 2011-8981 CIVIL TERM Defendant. ) PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER OqSSOCIATES, P.C. Attorn s Pr Plaintiff A Law Firm E , ag d in Debt Collection By: David J. A raker, Esquire I I IIII IIIII IIIIII IIIII * 4 3 1 7 3 9 9 S S 0 J 1 -