HomeMy WebLinkAbout12-5090
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LVNV FUNDING LLC In the Court of Common Pleas of I,
c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania
120 North Keyser Ave. Civil Division
Scranton, PA 18504
Plaintiff /y
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Roxanne Kosaber PRAECIPE FOR ENTRY OF JUDGME ~ ~ ; r`=-~
1664 SHAWNEE RD crri" _
SIDMANPA 15955-5301 ~
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Defendant
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To the Prothonotary of CUMBERLAND County:
1) Enter Judgment on the attached Exemplified Record of Judgment from Cambria County.
A) Date of Instrument: December 13, 2010
B) Amount of Judgment: $15,455.54
C) Interest From: December 13, 2010
2) Enter the judgment in favor or the original holder, or (unless expressly forbidder) in the ins ent)
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:
Roxanne Kosaber
1664 SHAWNEE RD
SIDMAN PA 15955-5301
ichael F. Ratchford, Esquire Atto ey for Phlintiff
Michael F. Ratchford, Esquire
Edwin A. Abrahamsen & Associates, P.C.
120 N. Keyser Ave ~ 33 . P 0 A7TJ
Scranton, PA 18504 ~ ~RfQb ~9Q18
570-558-5510 Ext. 101
Attorney ID 86285 7Q fa f
~t0{1Cl°. d~ ~e~Y
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LVNV FUNDING LLC In the Court of Common Pleas of II
c/o Edwin A. Abrahamsen & Assoc. CUMBERLAND County, Pennsylvania
120 North Keyser Ave. Civil Division
Scranton, PA 18504
Plaintiff
NO:
vs.
Roxanne Kosaber AFFIDAVIT UNDER SOLDIERS AND SAILORS
1664 SHAWNEE RD RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDE
SIDMAN PA 15955-5301.
Defendant
State of Pennsylvania
County of CUMBERLAND SS:
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the abov
named defendant(s): Roxanne Kosaber 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): Roxanne Kosaber is(are) older than eighteen years of age;
That the employment status of the defendant(s): Roxanne Kosaber is(are) unknown.
Mich 1 F. Ratchford, squire
Subscribed before me this~day of O~,L~
Notary Publi
COMMONWEALTH OF PENNSYLVANIA
Notarial Scat
Dana L. Stillarty, Notary! Public
City of Swanton, Wdcawan~ha County
COnlrtlipl0fl ]ul 21, 2015
M M9ER, PENNSYWANIA A550CiA'II OF WOTARIES
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IN THE COURT OF COMMON PLEAS OF CAMBRIA COUNTY, PENNSYLVANIA
OFFICE OF THE PROTHONOTARY
LNtJ1~N F4l~l~ LLC
assy~n~ of CI!T.t~R~~
%t~fffsl
91(Q: 201a-1748
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De,
fin~ant(sJ
~fE~'E4~S 1.S?" ~G'41
Ganrishee
CERTIfICATION OF DOCKET ENTRIES AND JUDGMENT
I, DEBBIE MARTELLA, PROTHONOTARY of the Court of Common Pleas of Cambria
County, Pennsylvania, do hereby certify that the following is a true, correct and full copy of the docket
entries in the above captioned case.
(SEE DOCKET ENTRIES)
I further certify that judgment was entered in favor of LVNV FUNDING LLC as n ' of CITIf3AN
plaintiff(s), and against, ROXANNE KOSAII~R ,defendant(s),
on the 13th day of December, 2010 in the above captioned case in the amount of
S 15,455.54
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the Seal of the said
Court, on the 13th day of July, A.D. 2012
Debbie Martella othonotary
By:
Deputy
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Plaintcffls)
ti~sus
Dcfe~ndan~(sJ
J~[EJK~t~~S 1~I' ~C~U
Ganti.~ee
CERTIFICATION OF DOCKET
ENTRIES AND JUDGMENT
JUDGMENT $15,455.54
Int. from
Cambria Co. Costs $143.00
This Record $10.00
MICHAEL F RATCHFORD ESQ
PLAINTIFF'S ATTORNEY
PYS511 Cambria County Prothonotary Page 1
Civil Case Print
•2010-01748 LVNV FUNDING LLC ET AL (vs) ROXANNE KOSABER II
Reference No... Filed......... /26/2010
Case Tyyppe.....: CONTRACT - DEBT COLLEC Time...... 1,1:20
Judgment..... 15,455.54 Execution Date /20/2012
Judge Assigned: Jury Trial....
Disposed Desc.: Disposed Date. /00/0000
Case Comments Higher Crt l.:
Higher Crt 2.:
General Index Attorney Info
LVNV FUNDING LLC PLAINTIFF RATCHFORD MICHAEL F SQ
ASSIGNEE
15 SOUTH MAIN STREET
GREENVILLE SC 29601
CITIBANK PLAINTIFF RATCHFORD MICHAEL F SQ
15 SOUTH MAIN STREET
GREENVILLE SC 29601
KOSABER ROXANNE DEFENDANT
781 BAUMGARDNER ROAD
SOUTH FORK PA 15956 3400
MEMBERS 1ST FCU GARNISHEE
401 EAST KING STREET
SHIPPENSBURG PA 17257
Judgment Index Amount Date Desc
KOSABER ROXANNE 15,455.54 12/13/2010 DEFAULT MENT
KOSABER ROXANNE 6/20/2012 WRIIT OF EX CUTION
* Date Entries *
4/26/2010 COMPLAINT IN CIVIL ACTION ANDRNOTI ERYFILED.
AMOUNT OF DAMAGES CLAIMED: SEE PAPE~t.
5/03/2010 SI~ER FF RETURN RECEIVED.
4/28 10 C~ 13:OSHRS-SERVED THE COMPLAINT WITH NOTICE', TO DEF ND UPON
RO E KOSABER, BY HANDING A TRUE & ATTESTED COPY THEREOF TO HER,
PERSONALLY ETC
SHFF KOLARSS COSTS PAID BY PLFF'S ATTY: $29.00
12/13/2010 PRAECIPE FOR DEFAULT JUDGMENT FILED BY MICHAEL F RATCHFO ESQQ
JUDGMENT ENTERED IN FAVOR OF PLAINTIFF AND AGAINST DEFEND I13~~
DEFAULT OF AN ANSWER, IN THE AN~OL~'I' OF: ~15 455.54~5$E PA ER) .
JUDGMENT ENTERED AND INDEXED. S PATTY ER{CEBILE, R4TION TARY.
PROTHONOTARY'S NOTICE OF ENTRY O JUDGMENT ISSUED THE D FENDANT.
IMPORTANT NOTICE DATED SEPTEMBER 22 2010, FILED.
AFFIDAVIT OF NON-MILITARY SERVICE, FILED.
CERTIFICATE OF SERVICE, FILED.
6/20/2012 PRAECIPE FOR ENTRY OF APPEARANCE ON BEHALF OF THE P~,AINTIF FILED
BY MICHAEL F RATCHFORD ESQ.
6/20/2012 PRAECIPE FOR WRIT OF EXECUTION FILED.
AMOUNT DUE• $15,455.54.
INTEREST: $1,344.00.
PLUS COSTS
WRIT OF EXECUTION AND INTERROGATORIES ISSUED TO THE'SHERIF .
7/13/2012 CERTIFICATION OF DOCKET ENTRIES ISSUED TO: MICHAEL F RATCH ORD ESQ.
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - -
* Escrow Infor ation *
* Fees & Debits Bed Bal P~mts~Ad~ End Bal
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PYS511 Cambria County Prothonotary ',Page 2
` Civil Case Print
+2010-01748 LVNV FUNDING LLC ET AL (vs) ROXANNE KOSABER
Reference No. Filed......... /26/2010
Case Type.....s CONTRACT - DEBT COLLEC Time........ 1,1:20
Judgment..... 15,455.54 Execution Date /20/2012
DisgosedsDescCase Comments DisposedaDate. /00/0000
P Higher Crt 1.:
Higher Crt 2.:
TAX ON CMPLT .50 .50 .00
JCS/ATJ FEE * 23.50 23.50 .00
AUTON~ATION FEE 5.00 5.00 .00
JDMT/DFLT WRIT .50 .50 .00
GARNISHEE .50 .50 .00
CERT OF DOC ENT 10.00 10.00 .00
COMP INT-C.A. 50.00 50.00 .00
JDMT~DEFAULT 14.00 14.00 .00
WRIT OF EXEC 20.00 20.00 .00
124.00 124.00 .00
* End of Case Information *
EXTRACTfROM THE R -CORD
CL'RTIFIED THIS. DAY OF
A. . 20,~
PR T NOTARY
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LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CAMBRIA County, Pennsylvania
Civil Division
vs.
NO: 2010-1748
Roxanne Kosaber
304 SHIPPENSBURG RD
Shippensburg PA 17257 Request for Exemplified Record of Judgment
Defendant
To the Prothonotary of CAMBRIA County Pennsylvania:
Please enter this Request for Exemplified Record of Judgment to transfer the Judgment to
Cumberland county.
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Thank you, :
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Michael F. Ratchfor s ire w ~.W.
Edwin A. Abraham n & Associates, P.C.
Lawyer ID # 8628
Sworn and subscribed before me on this day 20
otary ~ blic ` _
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Ct4L rrt ~cr~sP ~4'~, ,
RECEIPT FOR PAYMENT ~
Cambria County Prothonotary Receipt Date 7/13/2012
Ebensburg, Pa 15931 Receipt Time 10:36:06
Receipt No. 1153937
LVNV FUNDING LLC ET AL (VS) ROXANNE KOSABER
Case Number 2010-01748
Received of EDWIN A ABRAHAMSEN &
ASSOCIATES PC
Total Non-Cash..... + 10.00 Check# 48446
Total Cash......... + .00
Change - .00
Receipt total...... _ $10.00
Distribution Of Payment
Transaction Description Payment Amount
CERT OF DOC ENT 10.00 CAMBRIA COUNTY TREAS RER
$10.00
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Results as d : Aug-0rr 1208:43:39
Department of Defense Manpower Data Center
SCRA 222
R+dt
P'urw~# t+a ~'Grvieem~mbc~ Civil Relief Act
Last Name: KOSABER First Name: ROXANNE
Active Duty Status As Of: Aug-06-2012
Ar~Ye nub Sion Ili AalvrDuly Ena De+e ~Mddr canaon.nt
a; Acwe Dr+ri tai+ b taw
NA NA No NA
This response reflects the individuals' active duly status based on the Active Duly Staters Date
LeflAt~bei~ulyYrufir3HDryadAC~trel3lt~r~blgagi4e'
` Adve Wq' S9trt . , , licuge thrly E+d DoOie Shrti+t ' . Sr«vi[+ti CVmpap4M
NA NA No NA
This response reflects where the individual left active duty status withal 367 days preceding the Active Duty SlaWS Dam
Tyra r~4onrMr «F4tliar UaillNas Mo11Rrd d s-F1urGaMdlpfa~lrl~+ [~rarAr~r? ,fSt~WIF1we
t7rdartMoMtlAlan limn FYiF,, ~ Order Nolflfr~lion Fred {31he 311rwt ~ ~ Srrdoe fornFpriarg
NA NA No NA
This response reflec7s whether the individual « hislher unN has received early notification to report t« adive 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 talus of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NgAA, Public Heal ,and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
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The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and EI gibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Ad (50 USC App. §501 et seq, as amended) (SCRA) (formerly kn as
the Soldiers' and Sailors' Civil Relief Ad of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that t
individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any mily
member, friend, or representative asserts in any manner that the individual was on alive duty for the alive duty status date, or is otherwise entiti to the
protections of the SCRA, you are strongly encouraged to obtain further verifigtion of the person's status by contacting that person's Service via the
"defenselink.mil" URL: http:/lwww.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty s atus
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 5Q USC App. § 52 (c).
This response reflects the following information: (1) The individual's Alive Duty status on the Active Duty Status Date (2) Whether the individual le Active
Duty status within 367 days preceding the Alive Duty Status Date (3) Whether the individual or his/her unit received early notification to report for dive
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 peri s 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 servi
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency deGared by th
President and supported !iy Federal. funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization positio in the
unit they support. This includes Navy Training and Administration of the Reserves ('fARs), Marine Corps Active Reserve (ARs) and Coast Guard R serve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an alive duty commissioned officer of the .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 of be
reported as on Alive Duty under this certficate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services rinds.
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 alive 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 rvice.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be irxlruded, but who h e not
actually begun alive duty or actually reported for induction. The Last Date on Alive Duty entry is important because a number of protections of th SCRA
extend beyond the last dates of alive 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 CRA
are protected
WARNING: This certificate was provided based on a last name, SSN, and alive duty status date provided by the requester. Providing erroneous
information will cause an erroneous certificate to be provided.
Report ID: 129AJD1161
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LVNV FUNDING LLC In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
Plaintiff '
NO:
vs.
Roxanne Kosaber •
1664 SHAWNEE RD NOTICE OF FILING JUDGMENT
SIDMAN PA 15955-5301
Defendant
Notice is herby given that a money judgment in the above-caption d matter has been entered aga nst
you in the amount of $ /5 , .f,~'_ on
,
ay: ~ _
If you have any questions regazding this notice, please contact the filing pazty:
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)
LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
VS.
Roxanne Kosaber
1664 SHAWNEE RD NO: 12-5090
SIDMAN PA 15955-5301
Defendant
Praecipe to Dissolve the Attachment against
vs. Garnishee
MEMBERS 1 ST FCU
401 EAST KING ST
SHIPPENSBURG, PA 17257
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
Edwin A. Abr
Lawyer ID # 8
Esquire
& Associates, P.C.
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Sworn and subscribed before me on this day of 20 J Z
#9.50 p13 P ul",
e-0519-73
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff -'LED-CIr f°`I CE
Jody S smith �,�" DF THE PROTtjoNi ��nl;;
Chief Deputy
2013 APP -5 PM 3µ S
Richard W Stewart ~
Solicitor OFFICE OF THE"RIFF CUMBERLAND COUNT y
PENNSYLVANIA
LVNV Funding, LLC
Case Number
vs. 2012-5090
Roxanne Kosaber
SHERIFF'S RETURN OF SERVICE
09/20/2012 10:18 AM-William Cline, Deputy Sheriff,who being duty swom according to taw, states that on
September 20, 2012 at.1018 hours, attached as herein commanded all goods, chattels, rights, debts,
credits, and monies of the within named defendant,to wit: Roxanne Kosaber, in the hands, possession,
or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle,
Cumberland County, Pennsylvania, by handing to Tina Maslanik,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 28,2012 to Roxanne Kosaber at
1664 Shawnee Road, Sidman, PA 15955.
04/05/2013 Ronny R.Anderson, Sheriff,who being duly swom according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $88.40 SO ANSWERS,
April 05, 2013 RbNtrY R ANDERSON, SHERIFF
tea.. �..
',�A gg5y
r.)CounfySu:e S?leriff,'r'elaosott,Inc
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 12-:5490 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
f
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due LVNV FUNDING,LLC., Plaintiff(s)
From ROXANNE KOSABER,1664 Shawnee Rd,Sidman,PA 15955-5301
(I)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,401 East King Street,Shippensburg,PA 17257
Any and all accounts of the defts 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: 192-62-0552
and to notify the garnishees)that:(a)an attachment has been issued;(b)the garnishees) 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 $15,455.54 L.L.$.50
Interest -- $10.16
Atty's Comm % Due Prothy $2.25
Atty Paid $208.00 Other Costs
Plaintiff Paid
Date: 9/17/12
vid D.Buell,Prothonotary
(Seal) <—B y: AJO.-L 09vaur-441-
Deputy
REQUESTING PARTY:
Name: MICHAEL F.RATCHFORD,ESQUIRE
TRUE COPY FRC?81! RECORD
Address: EDWIN A.ABRAHAMSEN&ASSOCIATES,PC in Twstimorrir l hw►e unto set my hand
120 NORTH KEYSER AVENUE wrxl a CwrYsa,Pw.
SCRANTON,PA 18504 Prothon AWY
Attorney for: PLAINTIFF
Telephone:570-558-5510 Ext.1101
Supreme Court ID No.86285