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HomeMy WebLinkAbout12-1222Z COMMONWEALTH OF PENNSYLVANIA COUNTY O•F CUMBERLAND Mag. Dist. No: MDJ-09-1-01 MDJ Name: Honorable Charles A. Clement Jr. Address: Olde Towne Commons 400 Bridge Street, Suite 3 New Cumberland, PA 17070 #-'Po l? lpa? ?cV'( RNotice of Judgment'Transcript Civil Casc LVNV Funding LLC' Ebony Sco? c-'p Telephone: 717-774-5989 David J Apothaker, Esq. 520 Fellowship Road C-306 Mount Laurel, NJ 08054 Disposition Summary Docket No: MJ-09101-CV Case Filed: 8/1/2011 Docket No Plaintiff Defendant Disposition Disposition Date MJ-09101-CV-0000335-2011 LVNV Funding LLC Ebony Scott Default Judgment for Plaintiff 11/04/201' Judgment Summary Participant Joint/Several Liability Individual Liability Amount Ebony Scott $0.00 $1,370.57 $1.370.57 LVNV Funding LLC $0.00 $0.00 $0.00 Judgment Detail (*PostJudgment) In the matter of LVNV Funding LLC vs. Ebony Scott on 11/04/2011 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $1,248.82 $1,248.82 Costs $0.00 $121.75 $121.75 Grand Total: $1,370.57 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 JUDGMENTITRANSCRIPT 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. &Zug Date Magisterial District Judge Charles A. Clement Jr. __ _ ! certify that this is a true an correct copy o the record o the proceedings containing the judgment. I C, i "I, ' Date,:' Magisterial [district tud arles A. Clement Jr; ;. MDJS 315 Page 1 of 2 Printed:. 1110412011 1:23:51 PM f` 'E> a hE PROTHONO TAk , 2012 FEB 2 7 PM 2: 12, CUMBERLAND COUNT`: PENNSYLVANIA Qru-? IS a _a ago C.Q Our File No.: 320402 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: EBONY SCOTT 2211 CEDAR RUN DRIVE EXT CAMP HILL, PA 17011 LVNV FUNDING LLC Plaintiff vs. EBONY SCOTT Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: NOTICE Pursuant to Rule 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esquire at this telephone nu r: 0-672-0215 l , rr % g 9 -7 I 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. NO 12-1222 Civil Term CIVIL ACTION — LAW EBONY SCOTT WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against EBONY SCOTT, 2211 CEDAR RUN DRIVE EXT, 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 MEMBERS 1ST FCUGARNISHEE(S), as garnishee, 1711 SPRING ROAD, CARLISLE, PA 17013- ALL ZWIL L ASSETS AND ACCOUNTS, INCLUDING, BUT NOT LIMITED TO, BANK ACCOUNTS, BROKERAGE FIRM ACCOUNTS, STOCKS, CD'S, INSURANCE, SAFETY DEPOSIT BOXES, ETC. (Specifically describe °kit') 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 1 t 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 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 $1,370.57 Interest FROM NOVEMBER 4, 2011 - $196.91 Attorney's Comm. % Attorney Paid $60.25 Date: 5/30/14 (Scat) REQUESTING PARTY: Name : DAVID J. APOTHAKER, ESQUIRE Address: APOTHAKER & ASSOCIATES, P.C. 520 FELLOWSHIP ROAD, C306 MT. LAUREL, NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs $210.25 DAA bTELLEU David D. Buell, Prothonotary By: MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $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 Our File No.: 320402 LVNV FUNDING LLC Plaintiff vs. EBONY SCOTT ,-da l IC Cedar P- brine_ Defendant(s) earnp 14,11 PA 1'70lf IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 2012 -1222 -CIVIL To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; (2) against EBONY SCOTT, defendant(s); and PRAECIPE FOR WRIT OF EXECUTION (3) against MEMBERS 1ST FCU 1711 SPRING ROAD CARLISLE, PA 17013, Garnishee(s); (4) and index this writ in the judgment index (a) against EBONY SCOTT, defendant(s), and (b) against MEMBERS 1ST FCU 1711 SPRING ROAD CARLISLE, PA 17013, as Gamishee(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 $1370.57 Interest from November 04, 2011 $196.91. Minus Payments made -$ Plus Costs $210.25 Total $1777.73 David J. Apot -r, Esquire Attorney for Plaintiff(s) aa. co D rtP 8145 CBF $ Laos- Pb wry 4. a. as du90 .60 LL aff 1oaI43 fe."3aWeiO Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t - THE PROjH NOFti'ti 201 UN -9 Pi 3: Q`3 OFFICGQFTHS SkERIFF CUMBERLAND COUNTY PENNSYLVANIA LVNV Funding LLC vs. Ebony I Scott Case Number 2012-1222 SHERIFF'S RETURN OF SERVICE 06/06/2014 10:49 AM - Christopher Sharpe, 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, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Kathleen Nissley, Registered Sales Assistant, 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 9, 2014 to Ebony Scott, 2141 Cedar Run Drive, Apt. 304, Camp Hill, PA 17011. r O//-Z PHER SHARPE, DEPUTY SO ANSWERS, June 09, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosott, 'nc. Our File No.: 320402 LVNV FUNDING LLC Plaintiff vs. EBONY SCOTT 2211 CEDAR RUN DRIVE EXT CAMP HILL, PA 17011 XXX -XX -2847 Defendant MEMBERS 1ST FCU Garnishee ) ) ) COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY ) ) NO.: 2012 -1222 -CIVIL INTERROGATORIES TO GARNISHEE 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 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? - 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)? ± l E-Vo"t 0 `S • nS l e.- a� on3. At 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? N 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? .p 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 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. Accau,A,- a^71 '756 yea Sc) ,u\Seco-1A-N P ccOu".4 ) g'6V1-0-- IJ011/4.)F 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 generalexemptionunder -42-PA.C.S.§8123? If so, identify - each account. v ca la (A2g-, 9. How much is the value of any property in your possession belonging to the defendant(s)? g 9 toe. 4/3 10. In the space below, the plaintiff may set forth additional appropriate interrogatories. Dated: 40 David J. Apo ake . " squire APOTHA ASSOCIATES, P.C. 520 Fellowship Re : d C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff i:;LED-OFF THE PRO Jf LVNV FUNDING LLC, 2011: JUN 19 FM 3' Plaintiff CUMBERLAND COUNT PENNSYLVANIA v. EBONY SCOTT Defendant v. MEMBERS 1ST FCU, Garnishee Countp:of Qtutnberlattb IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2012-01222 CIVIL ACTION IN RE: CLAIM FOR EXEMPTION ORDER OF COURT AND NOW, this 19th day of June 2014, upon review of the Claim for Exemption filed by Ebony Scott, Defendant is entitled to the $300.00 statutory exemption by law. Further, Defendant is entitled to claim an exemption for her wages pursuant to 42 Pa.C.S. § 8127. Although Defendant did not claim an exemption for Social Security benefits deposits, and it appearing that Garnishee's Answers to Interrogatories indicate deposits of Social Security Funds, the Court, sua sponte, recognizes that the Social Security Act provides an exemption from attachment and garnishment for moneys paid as benefits. It is ORDERED and DIRECTED that Members 1st FCU shall release for Defendant's use, on a monthly basis, ithe directly deposited wages and any Social Security benefits of Defendant. All other accounts in or deposits to Members 1st FCU, other than aforementioned wage and Social Security direct deposits, remain subject to the garnishment of 30 May 2014. BY THE COURT, Thomas A Placey C.P.J. Distribution List: -K David Apothaker, Esq. Ebony Scott embers 1st FCU .a b//9/pi =-rn RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy coop of Cumber, ijio OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 June 13, 2014 Cumberland County Court Administration 1 Courthouse Square Carlisle, PA 17013 RICHARD W. STEWART Solicitor Enclosed please find a Claim for Exemption, pertaining to Cumberland County Civil Case Number 12-1222, filed by Ebony Scott, which was received in the Cumberland County Sheriff's Office on this date. Please note that there was bank garnishment ONLY done in case. If a hearing is scheduled, please forward a copy of the Notice of Hearing to my attention in the Sheriffs office, however it is the Court's responsibility to notify all parties involved. Thank you for your consideration to this matter. Sharon R. Lantz Staff Assistant Involved Parties: David Apothaker, Esquire Apothaker & Associates 520 Fellowship Road, Ste C306 Mt. Laurel, NJ 08054 800-672-0215 Ebony Scott, Claimant 2141 Cedar Run Drive, Apt. 304, Camp Hill, PA 17011 717-877-3610 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : WRIT NO. 2011 1122- CIVIL TERM CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy, or attachment: 1. From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): (ii) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): 2. Frorn my property which is in the possession of a third party, I claim the following exemptions: (a) my $300 statutory exemption: ❑ in cash ❑ in kind (specify property): (b) Social Security benefits on deposit in the amount of $ (c) other (specify amount and basis of exemption): 0‘, Rusw(1� Id-wtR Al f • Ai Acre 1 sI 1t_ s, ILIA ,ktiN CPIC64 F- 41 t\b\13 OM OA- ►' kt-(\;-- `'\-\ifik" VVP155 6`..- 41AIS Akft"4\* ePri\ W\( fit. I request a prompt court hearing to determine the exemption. Notice of the hearing of the hearing should be given to me at: llLt CQr R2\ be1 c369Address cptl \\\ Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: /j3j,t ti THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 i i Our File No.: 320402 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC ) Plaintiff ) vs. ) EBONY SCOTT ) NO.: 2012-1222-CIVIL Defendant ) `_ MEMBERS 1 ST FCU Jr •'c. Garnishee PRAECIPE TO ENTER JUDGMENT AGAINST THE GARNISHEE TO THE PROTHONOTARY: Enter judgment against the garnishee: MEMBERS 1 ST FCU for the following property of the defendant admitted in his answers to interrogatories to be in said garnishee's poss sio in the amount of: $668.43 David J. Apothaker, A&q6ire APOTHAKER SCIAN P.C. I IL I C - P I 4+ I i Our File No.: 320402 TO: MEMBERS 1 ST FCU 1711 SPRING ROAD CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC ) Plaintiff ) VS. ) I EBONY SCOTT ) NO.: 2012-1222-CIVIL Defendant ) MEMBERS 1 ST FCU ) ) Garnishee ) i NOTICE IS GIVEN THAT A JUDGMENT IN THE OVE APTIONED MATTE HAS BEEN ENTERED AGAINST YOU. I r 44 DAVID D. BUELL '�3l PROTHONOTARY IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CONTACT: i David J. Apothaker, Esquire Attorney for Plaintiff 520 Fellowship Road C306 PO BOX 5496 Mount Laurel,NJ 08054 800-672-0215 i i i v Y . JUN-11-2014 WED 10:49 AM MEMBERS IST MEMBER SVCS_ FAX NO, 7177956005 _ P. 01/03 A MEMBERS I" FUDERALCREDIT UNION To: Shannon Aute: 0. Company: Apothaker&Asspciates No. of pages including cover, —3— From: Alice McCloskey (800)283-2328,ext. 6022 fax: (717)795-6006 Interrogatories for 1✓bony Scott File 4320402 i 7 E i { i 5000 Louise Drive, P.Q.Box 40,Mechanicsburg,PA 17055 www.membersist.org We put our members first. I i i . JUN-11-2014 WED 10:49 AM MEMBERS IST MEMBER SVCS FAX NO. 717795600 _— 5 P. 02/03 06/11/2014 WEIR 10135 FAX 856 780 1020 Baa mombart firof U002/003 Our Vila No.: 120402 Y,VNt,!,FJJNnTNt,I.,t.1C. } C,UURI'Ul' COMMON PLEAS Ole !'ltsintiff } CUMBLR.LA.NI)COUNTY vs. } EBONY SCOTT } 2211 CEDAR RUN UIUVE EXT } NO.: 2012-1222•CIVIL CAMP i HILL, PA 17011 ) XXX-XX-2817 ) Civil Action Deft"noant ) MGMSERS IST FCU ) GAritishac SUPPLUMEN`Y'.A.L INN +11MOCATORTP"TO CARNISURF, TO: MEMSE" 1ST FCU,Garnishee: You are rcquired to file answers to tite fbilowing Interrogatories within twenty (20) days alter serviue � }I upuu you, FIjilure to do so[nay rastill,in,jodgment agailist you. t. At the time you were served or at any subsequent time did you owe the ilefeudani(s)any money or were you liable to defondant(s) oil any negotiable or tither wtytteat instrumcint, or did defendant(s) claim that you owed derentlant(s)any money or were liable to defendamt(s)for any reason? 2. At the time you were served or at any subsequent time was there in your pussc.uion,custody,i=trol t or in the .joint possession,custody or control of yotirsolf and one or more persons tiny pivp4rty of airy mature owned solely or in part by the detendant(s)'t 1 3(,(4,cj41 b 3. At the time you wum scrvcd or any subsequent time slid you hold legal titio to any property of any nature awed solely or in pai-t by the defenduni(s) or in which the defonthtril bolt! or claimed ally interest? ' 4. At the time you worc served or at any subsequent time did you hold as fiduciary any property in which 1114 dufuntltis2t(ti)lmd tiny interost? K)(�y 5. At any time befbre or alter you were served did the defientlunl(s) lramrcr or tlelivor any property to YOU Or to any person or place pursuant to your direction or Consent and what was the consideration thcivul'1 p 6. At any tine lifter you were served did yon pay, trimsfer or delivor imy manety or property to tlic delb(Idaln.(s) or to ally person or place pursuant to the defendant's direction or otherwise discharge -my claim ortlse JQrClIdalil(s)itg<niityi you? i • JUN-11-2014 WED 10:49 AM MEMBERS IST MEMBER SVCS FAX N0. 7177956005 P. 03/03 06/11/2014 w190 1.0: 35 FAX 956 790 1020 mai membexa fird� i It 7. 11'you arc a batik pl clther'tinancitll illstituti0n,atthetillleYOU Were sempti u�e�trcnlicaSly alit] the defenclunt(s) Iluve funds un dcPosit ul al7 aci�tunk in which funds thedeposited are recurring basis nnci which tiro identilic:d Ns being al 1�w1?A1�y�,lIdclentfy etchx�c�aunG �nci aei;�lc�diha __ ... levy or nttacllmclit under Fellnsylvallia or F rau5uzl'foi'thc cK.crnption and the entity electl�an`! -6 CT, �tC�sr funds an n recurring basis.time P a� posit, not S. It you are d bnnlc or other financial institution,sit i111An accpu 1t i�Y he thne you ,N-wluaii tiieVol rfuuds an at any it uen ' Old lho cicl'Gridallt(s) have ILOUIS X711 deposit including ally oihc"rwiso exertipt fiends, dict .not exceed the ; of tel C.V-, �em�ltiun �$u Lou I.lrldur g2P11.C.S.§8 l23'? l;f so,identify each account, your Ly I c, 'w mur'l1 is tilts value of ally Pro�rlyour lyi}9bC5d1011171.1Q11�1ng to tel Q�9 �� ) Ila 10, ill tllc space below,the plaintiff lnay set folih additional nwpro}�riuta inlwrogHturicr�, i i T7stGd: �Ol � `{ — 1 David J. Apotbaker,FmquiTe j ALPOTHAKBR SCIAN P.C. 520 Fello'wslliP ROacl 0306 PU Box 5496 Mount LaUrel,New jersey OR054 (856)790-1000 Attomeys for Plaitltiff I ; i i i i i i Our File No.: 320402 Apothaker Scian P.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC vs. EBONY SCOTT Plaintiff, Defendant. ER JUL -3 PH 12: L a CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY ) ) ) ) ) ) ) NO. 2012 -1222 -CIVIL PRAECIPE TO VACATE JUDGMENT AGAINST THE GARNISHEE TO THE PROTHONOTARY: Please vacate the Judgment against the Garnishee. Apothaker Scian P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: Benjamin allaro, Esquire $4.5o ArtY CIIoBaO0 et 308000 V Sge),YOD s MEMBERS "1St FEDERAL CREDIT UNION June 16, 2014 David J Apothaker, Esquire 520 Fellowship Road C306 PO Box 5496 Mount Laurel, NJ 08054 RE: Writ of Executionfor Ebony Scott Dear Sir: A search of our records has revealed one account bearing the name Ebony I Scott with an address of 2141 Cedar Run Dr Apt 304, Camp Hill PA 17011. The account reflects an available balance of $668.43. Pursuant to the writ, all funds in the aforementioned accounts above and beyond the monetary exemption provided by 42 P.S. Section 8123 and Pa. Rule of Civil Procedure 3111.1(3) in the amount of $300.00 have been frozen. Except for the exempt funds in the amount of $300.00 which are statutorily not subject to attachment, the accounts have been restricted from any further withdrawal transactions. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 6022. Sincerely, Alice McCloskey Deposit Operations Analyst 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwmemberslst.org Our File No.: 320402 LVNV FUNDING LLC Plaintiff vs. EBONY SCOTT 2211 CEDAR RUN DRIVE EXT CAMP HILL, PA 17011 XXX -XX -2847 Defendant MEMBERS 1ST FCU Garnishee COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 2012 -1222 -CIVIL Civil Action 415 INTERROGARIES TO GARNISHEE TO: MEMBERS 1ST FCU, Garnishee: c.: 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? yi 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)? l kC,c`) 0 - ai-, scA<<- 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? Op 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. Pccx,rr 31 7 5 SoCck ACcour‘-k -4& ) 8702(210— 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. (Nscc__:,, _ (s(L) 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:4111 David J. Apoake squire APOTHA ASSOCIATES, P.C. 520 Fellowship R d C306 PO Box 5496 Mount Laurel, New Jersey 08054 (856) 780-1000 Attorneys for Plaintiff