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Home My WebLink About11-9145GORDON & 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 2106687 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual 500 Summit Lake Dr., Ste. Valhalla, NY 10595--134 VS. DANIELLE LEBO 329 W GRAND AVE TOWER CITY PA 17980-1015 and Members 1st FCU 1711 Spring Road Carlisle PA 17013 GARNISHEE COURT OF' COMMON PLEAS CUMBERLAND COUNTY 11-9145 CIVIL C") o r ... ar <? ' a C-) D Z rt Zc0 CDm DOCKET NO PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue writ of execution in the above matter, directed to the Sheriff of Cumberland County; (l) against DANIELLE LEBO defendant(s)and (2) against Members 1st FCU garnishee(s) (3) AMOUNT DUE $4,371.55 INTEREST from December 9, 2011 $41.63 COSTS Prothonotary fee Sheriff fee (4) Less: Payments on Account ( $.00) TOTAL O .$a9.00 PA ATTY a I S. 170 CBF a4. oo a.50 *ag4.ao - Po " 4a.as ow Co 5o 1,L FREDERIC I. W RG, ESQUIRE JOEL M. FLINK, ESQUIRE C# ((y?141 (o5350 Attorney for Plaintiff # oZ 71107 I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-9145 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAVALRY PORTFOLIO SERVICES, LLC, as assignee of CAVALRY SPV I, LLC, as assignee of CHASE WASHINGTON MUTUAL, Plaintiff (s) From DANIELLE LEBO, 329 W. Grand Avenue, Tower City, PA 17980-1015 (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, 1711 SPRING ROAD, 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,371.55 L.L. $.50 Interest from 12/9/11 -- $41.63 Atty's Comm % Due Prothy $2.25 Atty Paid $279.20 Other Costs Plaintiff Paid Date: 2/15/12 Davy uell, Protho otary (Seal) By: Deputy REQUESTING PARTY: Name FREDERIC I. WEINBERG, ESQUIRE Address: GORDON & WEINBERG, PC 1001 E. HECTOR STREET, STE 220 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 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 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual 500 Summit Lake Dr., Ste. Valhalla, NY 10595--134 VS. LEO-OFF ICE HE I POTHONOTA} ; 2012 FEB 23 AM !!: 214 CUMBERLAND COUNTY PENNSYLVANIA _ COURT OF COMMON PLEAS CUMBERLAND COUNTY RECE1HEID FEB 212012 DOCKET NO. : 11-9145 CIVIL DANIELLE LEBO 329 W GRAND AVE TOWER CITY PA 17980-1015 and Members 1st FCU 1711 Spring Road Carlisle PA 17013 GARNISHEE k6of J 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 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 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? q111-1 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. ()0 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. ()0 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? I/1O FREDERIC I. EII ERG, ESQUIRE JOEL M. FLINK, ESQUIRE DATED:'-,Yi , Attorney for Plaintiff 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? 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 his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? rl() 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. nD 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, identify each account. n D 9. How much is the value of any property in you _ possession belonging to the defendant (s) f*V1 St MEMBERS 1St FEDERAL CREDIT UNION February 21, 2012 Danielle Lebo 329 W. Grand Avenue Tower City, PA 17980 Review Dates (60 Days): December 24, 2011 - February 21, 2012 Total Writ of Execution: $4,695.13 Cumberland County Docket Number: 11-9145 File # Account Number: XXX202-0000 Name on Account: Danielle Lebo Savings: $464.68 -5.00 (Membership Fee) $459.68 -50.00 (Processing Fee) $409.68 Payroll: Good Samaritan H $300.00 Statutory Exemption was not taken out. Tania S. Youn Deposit Operations 4lyst Rev: 06/11 5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. J"U (SIGNA RE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson owLL1-;?;='li A Sheriff THLE Jody S Smith l7 Chief Deputy FEB 22 Pay! 3: 0.0 Richard W Stewart CUMBERLAND COiUHT`• Solicitor PENNS YLVf. IMA Cavalry Portfolio Services, LLC, as assignee of Cavalry SPV I, LLC, as Case Number vs. Danielle Lebo 2011-9145 SHERIFF'S RETURN OF SERVICE 02/21/2012 09:24 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on February 21, 2012 at 0924 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Danielle Lebo, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 401 E King Street, Shippensburg, Cumberland County, Pennsylvania, 17257 by handing to Luanne E. Kyle, 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. The writ of execution and notice to defendant was mailed on February 21, 2012 to Danielle Lebo at 329 W Grand Avenue, Tower City, PA 17980-1015. SO ANSWERS, February 21, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy I 0 2106687 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 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual VS. DANIELLE LEBO and Members 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9145 CIVIL NOTICE PURSUANT TO RULE 236 OF THE SUPREME COURT OF PENNSYLVANIA, YOU ARE HEREBY NOTIFIED THAT A JUDGMENT UPON ADMISSIONS HAS BEEN ENTERED AGAINST YOU IN THE ABOVE PROCEEDING. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL FREDERIC 1. WEINBERG, ESQUIRE AT 484/351-0500 31511A 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 Cavalry Portfolio Services, LLC as COURT OF COMMON PLEAS assignee of Cavalry SPV I, LLC as CUMBERLAND COUNTY assignee of Chase / Washington Mutual 500 Summit Lake Dr., Ste. Valhalla, NY 10595--134 ?M v> rD --4 C? ^A C:) -r ra «-C= - D VS. DOCKET NO. : 11-9145 CIVIL DANIELLE LEBO and Members 1st FCU Garnishee PRAECIPE FOR JUDGbZNT UPON ADMISSION TO THE PROTHONOTARY: Please enter judgment in favor of the Plaintiff, Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual and against the Garnishee, Members 1st FCU, in the amount of $109.68, admitted in the Answer to Interrogatories to be in the Garnishee's possession, together with interest. and costs which is not more than the amount of the judgment of the Plaintiff against the Defendant together with post judgment costs and post judgment interest which is $4,846.86. Date: 2212-1 T GORDON & WEINBERG, P.C. BY: FREDERIC I, E NBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff (a?V?? * 1(p. SO fo a* Iuur?N P. * Q `11 0t Sa Tv.w,e NNh.10 2106687 St MEMBERS 1" FEDERAL CREDIT UNION February 27, 2012 Joel M. Flink, Esq. Gordon & Weinberg PC 1001 E. Hector Street, Ste 220 Conshohcken, PA 19428 RE: Writ of Execution for Danielle Lebo Dear Mr. Flink: A search of our records has revealed one (1) savings account bearing the name Danielle Lebo with an address of 329 W. Grand Avenue, Tower City, PA 17980. The savings account reflects an available balance of $409.68. Pursuant to the writ, all funds in the aforementioned accounts have been frozen. The accounts have been restricted from any withdrawal transactions. Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the total balance of the account exceeds the general monetary exemption under 42 Pa. C.S. § 8123 and therefore are attachable. The full amount of the attachable funds is contained in the interrogatories as filed with the Cumberland County Prothonotary. Since the funds contained in these accounts are attachable, and the account has been restricted from any withdrawal transactions, any deposits will be held for attachment until the amount above is satisfied. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 5125. Sincerely, Tania S Young Deposit Operations Analyst Rev: 06/11 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org r GORDON & WEINBERG, P.C. 'BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 RECENED JOEL M. FLINK, ESQUIRE Identification No.: 41200 FED 21 2012 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual 500 Summit Lake Dr., Ste. Valhalla, NY 10595--134 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. DANIELLE LEBO 329 W GRAND AVE TOWER CITY PA 17980-1015 and Members lst FCU 1711 Spring Road Carlisle PA 17013 GARNISHEE DOCKET NO INTERROGATORIES IN ATTACHMENT TO: Members 19t FCU - GARNISHEE 11-9145 CIVIL t i L ! y o C) `Z7 . G'7 e'v -f ` z ;r m ?E:;u " r, M rrj- - ., r-- Cn r .-< D ru ;., rn &:p O t,1 "1 C- C7 d --TI O ' 52 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 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. ()a 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. f)() 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? r) a 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? 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 his(her, their) direction or otherwise discharge any claim of the defendant(s) against you? 00 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. I)U 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, identify each account. 9. How much is the value of any property in your possession belonging to the defendant(s) ? W UL DATED: '-Y1 1) FREDERIC I. "ERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff A MEMBERS 1st FEDERAL CREDIT UNION February 21, 2012 Danielle Lebo 329 W. Grand Avenue Tower City, PA 17980 Review Dates (60 Days): December 24, 2011 - February 21, 2012 Total Writ of Execution: $4,695.13 Cumberland County Docket Number: 11-9145 File # Account Number: XXX202-0000 Name on Account: Danielle Lebo Savings: $464.68 -5.00 (Membership Fee) $459.68 -50.00 (Processing Fee) $409.68 Payroll: Good Samaritan H $300.00 Statutory Exemption was not taken out. ju? -'? i 1? v Tania S. Young/ Deposit Operations ?Ilyst Rev: 06/11 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNA RE) L?7?1 26 ?, 2• d` GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE s Identification No.: 41360 COUNT JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual VS. DANIELLE LEBO and Members 1st FCU Garnishee COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9145 CIVIL ORDER TO SATISFY JVDG4ENT 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. GORDON & WEINBERG, P.C. BY: FREDERIC I. KE.INBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P013 Q,?{ ?9. Sa xl a ?. ck- * 16-76 to S OP 14g-o-73 Jz# a--?aq (D y 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 Cavalry Portfolio Services, LLC as assignee of Cavalry SPV I, LLC as assignee of Chase / Washington Mutual VS. DANIELLE LEBO 2106687 J f RR 23 Pp1 ! S a lESf PENNSYLVANIA ANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 11-9145 CIVIL ORDER TO SATISFY JUDGWENT TO THE PROTHONOTARY: Kindly mark the judgment entered December 9, 2011 in the above- captioned matter satisfied upon payment of your costs only. GORDON & WEINBERG, P. BY: FREDERI I. INBERG, ESQUIRE JOEL M. K, ESQUIRE Attorney for Plaintiff P005