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HomeMy WebLinkAbout12-4040LVNV FUNDING LLC In the Court of Common Pleas of c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania 120 North Keyser Ave. Civil Division Scranton, PA 18504 Plaintiff _ NO: 14 - IVo VO i / /erin vs. Robert Stitt PRAECIPE FOR ENTRY OF JUDGMENT c 70 E Main St w Plainfield PA 17081 r.n C- Defendant co E To the Prothonotary of CUMBERLAND County: r-; x? 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice"' A) Date of Instrument: February 6, 2012 B) Amount of Judgment: $2,109.89 C) Interest From: February 6, 2012 rn r? 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: Robert Stitt 70 E Main St Plainfield PA 17081 Michael F#gaichford, squir omey for TPlainntiffff 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 431.025 PO Al" 0,W 47008 8* 67-77a97 Noke Mai feel COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Mag. Dist. No: MDJ-09-3-02 MDJ Name: Honorable Vivian Cohick Address: 55 Penn Drive Newville, PA 17241 Telephone: 717-776-3187 Lvnv Funding C/O Edwin A Abrahamsen & Assoc., P.C 120 N Keyser Ave Scranton, PA 18504 Disposition Summary Docket No MJ-09302-CV-0000207-2011 Judgment Summary Participant Lvnv Funding Robert Stitt Notice of Judgment/Transcript Civil Case Plaintiff Defendant Lvnv Funding Robert Stitt Joint/Several Liability Individual Liability $0.00 $0.00 $0.00 $2,109.89 Lvnv Funding V. Robert Stitt ?OEMai it S' plainfiEld, PA 17DRI Docket No: MJ-09302-CV-0000207-2011 Case Filed: 12/27/2011 Disposition Disposition Date Default Judgment for Plaintiff 02/06/2012 Amount $0.00 $2,109.89 Judgment Detail (*Post Judgment) In the matter of Lvnv Funding vs. Robert Stitt on 2/06/2012 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 $2,007.89 $2,007.89 Costs $0.00 $102.00 $102.00 Grand Total: $2,109.89 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. l Date k' t??O- ?Jq -Ct_k?)L Magisterial District Judge Vivian Cohick N nt IN?Nh ?, yi?? certify at this is a true an correct copy o the record o the proceedings containing the judgment. Date Magisterial District Judge i ian Cohick MDJS 315 Page 1 of 2 Printed: 02/06/2012 10:48: 33AM F 1 ( o9aLI3 LVNV FUNDING LLC c/o Edwin A. Abrahamsen & Assoc. 120 North Keyser Ave. Scranton, PA 18504 Plaintiff In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: vs. Robert Stitt 70 E Main St Plainfield PA 17081 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Defendant 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): Robert Stitt 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): Robert Stitt is(are) older than eighteen years of age; That the employment status of the defendant(s): Robert Stitt is(are) unknown. Department of Defense Manpower Data Center jit, ;, 1 Ju n 04 2012 12:0246 SCRA 2.2 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: STITT First Name: ROBERT Active Duty Status As Of: Jun-04-2012 Active Duty Start Date Active Duty End Dale Status Service Component On Active Duty On Active Duty Status Date NA NA No NA This response reflects the individuals' active duty status haset on the Active Duty Staters Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Dale Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty stairs within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NP. NA .. No NA This response reflects whether the individual or his/her unit has received early norification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicernember or his/her unit receiving notification of future orders to report for Active Duty. .>r-M' 4?m_ ?j Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the DefencE ?,.c. r< fit rnd F ::iyibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility sr;ie rs. The DoD strongly supports the enforcement of the Service members Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) iformerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indi -'ating that the individual is currently on active duty" responses, and has experienced only 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 was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain 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.htmi- If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: THTRJCATPU LVNV FUNDING LLC In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Plaintiff ' vs. Robert Stitt 70 E Main St Plainfield PA 17081 NO: NOTICE OF FILING JUDGMENT Defendant : Notice is herby given that a money judgment in the above-captioned matter as been entered against you in the amount of $ /C )g. 89 on If you have any questions regarding this notice, please contact the filing party: 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) PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111 (a) LVNV FUNDING LLC G `_... In the Court of Common Pleas of 3: Plaintiff CUMBERLAND County,Pennsylvania Civil Division t vs. 4 ca- Robert Stitt 3"C'= c 25 FAIRFIELD STREET NO: 12-4040 CIVIL TERM Newville PA 17241 'mo t +C:, �: Defendant VS. PRAECIPE FOR WRIT OF EXECUTION AND ATTACHMENT M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 Garnishee (MONEY JUDGMENT) To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:Robert Stitt (3) And against:M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 (4) and index this writ(a)against Defendant(s)(b)against M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 Garnishee(s), as a]is pendens against the real property of the defendant(s)in the name of the Gamishee(s),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.Defendant's SSN(s): ***-**-5528; (5) Judgment Amount $2,109.89 Interest $.00 3q Payments $675.00 Clerks Fee $ Sheriff $ Poundage $ Total $ ( Date:August 15,2013 c� Michael .Ratchford, squde Edwin A.Abrahamse &Associates,P.C. V� Attorney for Plainti mratchford @eaa-1 com 1 ss ; ,� � r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 12-4040 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 ROBERT STITT,25 FAIRFIELD STREET,NEWVILLE,PA 17241 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: M&T BANK,28 WALNUT BOTTOM ROAD,SHIPPENSBURG,PA 17257-8219-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; (2) 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$1,434.89 Plaintiff Paid$ Interest Attorney's Comm. % Law Library$$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: Sept. 9,2013 David D. Buell,Prothonotary �Sc:af) Deputy REQUESTING PARTY: Name : MICHAEL F.RATCHFORD,ESQUIRE Address: EDWIN A.ABRAHAMSEN&ASSOCIATES,P.C. 1.20 N.KEYSER AVENUE SCRANTON,PA 18504-9701 Attorney for: PLAINTIFF Telephone: 1-800-503-1.665 Supreme Court ID No. 86285 LVNV FUNDING LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. G Robert Stitt ..ti Co V) vn t= 25 FAIRFIELD STREET NO: 12-4040 CIVIL TERM rn rn r"- Newville PA 17241 Defendants VS. CD M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 Garnishee Praecipe for Entry of Appearance Kindly enter my appearance on behalf of LVNV FUNDING LLC in the above-captioned matter. Date:August 15,2013 SignaAame: Print MichaelF.Ratch1ord, squire Address: 120 North Ke ser venue Scranton PA 1 04 Telephone No: 570 55 -5510 Ext. 120 Supreme Court ID No: 6285 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson 1€ Sheriff k�+t t trrtr�i r� 4,.:i` THE P'ROTH01wGr i��tc�, Jody S Smith �° y, '�'�� Chief Deputy 7.0 13 SEP 19 AM [1: 2 a Richard W Stewart -Y! � N�Y Solicitor CSPFI F OF Tot.S11=RIFF PENNSYLVANIA LVNV Funding LLC vs. Case Number Robert Stitt 2012-4040 SHERIFF'S RETURN OF SERVICE 09/12/2013 10:07 AM -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, M &T Bank, 1 West High Street, Carlisle, PA 17013, Cumberland County, by handing to Joan Crowell, Teller, 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 September 13, 201 to Robert Stitt at 25 Fairfield Street, Newville, PA 17241. WILLIAM CLINE, DEPUTY SO ANSWERS, September 13, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosof,Inc. LVNV FUNDING LLC In the Court of Cormnon Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division VS. Robert Stitt 25 FAIRFIELD STREET NO: 12-4040 CIVIL TERM fry Newville PA 17241 Defendant 4sGt?eRs 4o VS. INTERROGATORIES IN ATTACHMEN'� -C C) M&T BANK © 6-4 28 WALNUT BOTTOM RD ;r_-" SHIPPENSBURG PA 17257-8219 ° Garnishee - 7, RE: Execution of Judgment against your depositor Robert Stitt.SSN# ***-**-5528 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) and the primary account holder and if known whether joint account is entireties property. no 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? AO 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? A- 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? MO I 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.�D 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. A-0 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). I ►� Edwin A. r men&Ass pates,P B Mic ael F.Ratc ford, squire 120 North Key er A,enue Scranton,P 18504 l (570)55 - 10 Ext. 101 BAW SEP 17 200 LVNV FUNDING LLC . In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. Robert Stitt 25 FAIRFIELD ST NO: 12-4040 CIVIL TERM NEWVILLE PA 17241-1329 Defendant Praecipe to Dissolve the Attachment against vs. Garnishee M&T BANK 28 WALNUT BOTTOM RD SHIPPENSBURG PA 17257-8219 Garnishee t� 101" C,+` To the Prothonotary of CUMBERLAND County Pennsylvania: ' _) zz Please enter the above Praecipe to Dissolve the Attachment against Garnishee. " °r --I X.— 3 < c Thank you, ich WARatchf, re Ed win A. Abr sen& Associates,P.C. Lawyer ID # 8 85 at agU09a Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY w CIIPtaitt comE V' THE s14.5.pip.= 1E3- .2 THE POTHONO,1„-„ 20 lii APR 11+ 2:. t4 I OUMBE,RLAND COUNTY PENNSYLVANIA LVNV Funding LLC vs. Robert Stitt Case Number 2012-4040 SHERIFF'S RETURN OF SERVICE 09/12/2013 10:07 AM - 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, M & T Bank, 1 West High Street, Carlisle, PA 17013, Cumberland County, by handing to Joan Crowell, Teller, 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 September 13, 2013 to Robert Stitt at 25 Fairfield Street, Newville, PA 17241. 04/14/2014 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: $89.26 SO ANSWERS, April 14, 2014 tc) County Suite Shefiff, Teleasoft, RONNY R ANDERSON, SHERIFF