HomeMy WebLinkAbout13-7088 COMMONWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS NOTICE OF APPEAL
Judicial District, County Of CUMBERLAND FROM
MAGISTERIAL DISTRICT JUDGE JU
COMMON PLEAS No. —� D D U
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the Magisterial District
Judge on the date and in the case referenced below.
NAME OF APPELLANT MAG. DIST. NO. NAME OF MDJ
LVNV FUNDING LLC 09 -3 -04 HONORABLE PAULA P. CORREAL
ADDRESS OF APPELLANT CITY STATE ZIP CODE
15 SOUTH MAIN ST GREENVILLE Sc 29601
DATE OF JUDGMENT IN THE CASE OF (Plaintiff) (Defendant)'
11/5/13 LVNV FUNDING LLC �s LIFFORD BROWN
DOCKET No. SIGNATURE PPELLANT 0 TTO EY 0 G
CV- 170 -13
This block will be signed ONLY when this notation is required under Pa. )f app lan w aimant (see Pa. R.C.P.D.J. No. 1001(6) in action
R.C.P.D.J. No. 1008B.
This Notice of Appeal, when received by the Magisterial District Judge, II before a Magisterial District Judg , A COMPLAINT MUST BE FILED
operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty
(20) days after filing the NOTIC of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellant was DEFENDANT (see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District
Judge. IF NOT USED, detach from copy of notice of appeal to be served upon appellee.
PRAECIPE: To Prothonotary
Enter rule upon appellee(s), to file a complaint in this appeal
Name of appellee(s)
(Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
Signature of appellant or attorney or agent
RULE: To appellee(s)
Name of appellee(s)
(1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service
of this rule upon you by personal service or by certified or registered mail.
(2) If you do not file a complaint within this time, a JUDGMENT OF NON PROS MAYBE ENTERED AGAINST YOU.
(3) The date of service of this rule if service was by mail is the date of the mailing.
t V "
Date: 20 f1
y 1 1` 4 �� r f Signature of Prothonotary or Deputy
YOU MUST INCLUDE A COPY OF THE NOT � ( FJ_PDGME, T/TRANSCRIPT FORM WITH THIS NOTICE OF APPEAL.
J41041 '11
Qh
AOPC 312 -05 CkA
COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND Case
Ao
Mag. Dist. No: f MDJ- 09 -3 -04 LVNV Funding LLC
MDJ Name: Honorable Paula P. Correal V.
Address: 5275 East Trindle Road Clifford Brown
Suite 110
Mechanicsburg, PA 17050
Telephone: 717- 697 -2201
LVNV Funding LLC Docket No: MJ- 09304 -CV- 0000170 -2013
c/o Edwin A. Abrahamsen @ Associates, P.C. Case Filed: 5/20/2013
120 North Keyser Avenue
Scranton, PA 18504
�..
Disposition Details
Dispositio"umma[ry c Cross complaint)
Docket No Plaintiff Defendant Disposition Disposition Date
MJ- 09304 -CV- 0000170 -2013 LVNV Funding LLC Clifford Brown Judgment for Defendant 11/05/2013
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH
THE PROTHONOTARYICLERK 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.
Date/ t Senior Magisterial District Judge Paula P. Correa[ ~^°�
certify a is is a true and correct cop7of the record of the procee rags containing t e )u gment.-
r
Date _ Ma iIt ertal Cislnct Judge
MDJS 315 Page 1 of 2 Printed: 11/05/2013 2:00:OOPM
r
1
LVNV Funding LLC Docket No.: MJ- 09304 -CV- 0000170 -2013
V.
Clifford Brown `
Participant List
Private(s)
Attorney Michael F. Ratchford, Esq.
Edwin A Abrahamsen & Associates_ PC
120 North Keyser Ave
Scranton, PA 18504
Plaintiff(s)
LVNV Funding LLC
c/o Edwin A. Abrahamsen @ Associates, P.C. l
120 North Keyser Avenue
Scranton, PA 18504
Defendant(s)
Clifford Brown
407 5th Street
Enola, PA 17025
MDJS 315 Page 2 of 2 Printed: 11/05/2013 2:00:OOPM
'Supreme Couft o: Pennsylvania
Court 6f COmmo*j?1eas For Prothonotary Use Only:
C1*it t Docket No: 1 fit l
CLIMB �RLANd /, , County � ors tt`
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by lava or rules of court.
Commencement of Action:
Complaint [3 Writ of Summons [3 Petition
n Transfer from Another Jurisdiction El Declaration of Taking
E Lead Plaintiff's Name: Lead Defendant's Name:
.0 LVNV FUNDING, LLC CLIFFORD BROWN
T,
Dollar Amount Requested: Owithin arbitration limits
I Are money damages requested? El Yes 0 No (check one) E] outside arbitration limits
U
% Is this a Class Action Suit? Yes No Is this an MDJAppeal? Yes 1l No
Name of Plaintiff/Appellant's Attorney: MICHAEL RATCHFORD
Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
j PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
1
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
Intentional ® Buyer Plaintiff Administrative Agencies
® Malicious Prosecution ® Debt Collection: Credit Card n Board of Assessment
® Motor Vehicle Debt Collection: Other Board of Elections
0 Nuisance ® Dept. of Transportation
® Premises Liability Statutory Appeal: Other
S 0 Product Liability (does not include
mass tort) Employment Dispute:
E Discrimination
0 Slander/Libel/ Defamation
� ®Other: ®Employment Dispute: Other Zoning Board
1
El Other:
T MDJ APPEAL
I 13 Other:
0 MASS TORT
Asbestos
N Tobacco
® Toxic Tort -DES
® Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Toxic Waste [3 Ejectment 1] Common Law /Statutory Arbitration
® Other: El Eminent Domain/Condemnation n Declaratory Judgment
0 Ground Rent ® Mandamus
13 Landlord/Tenant Dispute Non - Domestic Relations
Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Commercial El Quo Warranto
® Dental ® Partition ® Replevin
® Legal ® Quiet Title ® Other:
® Medical Other:
1 Other Professional:
j
Updated 1/1/2011
IN THE COURT OF COMMON PLEAS OF [ � 'i ' - ` , %If s��y f
CUMBERLAND COUNTY, PENNSYLVANIA 1 t DEC
LVNV FUNDING LLC •,, „ _ /1 5
15 South Main Street CIVIL ACTION PE N d Sryh C A T Y
Greenville, SC 29601
Plaintiff
vs. U v
1
NO:
Clifford Brown
407 5TH ST
EAST PENNSBORO PA 17025
Defendant
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice to
Defend are served, by entering a written appearance personally or by an attorney and filing in
writing with the court your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a judgment may be entered
against you by the court without further notice for any money claimed in the Complaint or for any
other claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE.
MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717- 243 -9400
R1300367
. w
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
15 South Main Street CIVIL ACTION
Greenville, SC 29601
Plaintiff
VS.
NO:
Clifford Brown
407 5TH ST
EAST PENNSBORO PA 17025
Defendant
COMPLAINT
Plaintiff, LVNV FUNDING LLC, by and through its attorneys, Edwin A. Abrahamsen &
Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, LVNV FUNDING LLC, (hereinafter "Plaintiff') is a corporation with a
principal place of business located at 15 South Main Street Greenville, SC 29601.
2. The Defendant Clifford Brown (hereinafter "Defendant ") is an adult individual
residing at 407 5TH ST EAST PENNSBORO PA 17025.
3. Defendant applied for and received a credit card issued by HSBC Bank Nevada,
N.A. with the account number ending in 1893.
4. The within account was sold by HSBC Bank Nevada, N.A. to LVNV FUNDING
LLC for valuable consideration and all rights under said accounts were assigned to LVNV
FUNDING LLC.
5. Use of the HSBC Bank Nevada, N.A. credit card was subject to the terms and
considerations of the Cardmember Agreement (hereinafter "Agreement "), a copy of which was
sent to the Defendant along with the credit card.
6. Defendant used the HSBC Bank Nevada, N.A. credit card account number ending
in 1893, for purchases, cash advances and /or balance transfers.
7. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
8. The Defendant last made payment on February 24, 2010.
9. The total amount due and owing the Plaintiff, including interest, is $7,t07.31.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $7,107.31 plus costs of suit and any other relief as the Court deems just and
appropriate.
Res p tfully s tte
rchael F. Ratc ord; squire
Attorney I.D. s.: 86285
120 N. Keyse Ave
Scranton, P 18504
mratchford - eaa- law.com
Phone: 800 -503 -1665
Fax: 570 -558 -5511
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff, LVNV FUNDING LLC, am fully familiar
with the facts set forth in the within Complaint and am authorized to make this Verification on
behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to
the best of my knowledge, knowing that any false statements are punishable by law pursuant to
18 C.S.A. 4904.
is ael F. Ratchf d, Esquire
y ,NNE.
EX_T:11DI.T A
ASSIGNMENT AND SILL OF SALE
HSSC Sank Nevada, IN.A., thereinafter calied °Sella €' ; has entered into an
Account Purchase and Sale Agreement as of February 16", 2.010 ( "Agreement'),
as amended, for the sa € e of Accounts and Account Documents described in
Paragraph I thereof to Sherman Originator Ill, LLG (hereinafter called
°Purchaser• " }, upon the terms and conditions set forth in that Agreement.
C�I,i TI REEpRE, for goad and valuable cQnside� a ion, Seller hereby
r
sells, assi and transfers to Purrhaser, lts successors and assigns all of
Seller's rights, title and irate ewt i n each and evert one of the Accounts descd bed
In the Agreement and in Exhibit A attached hereto.
Purchaser and Seller agree that the Purchase Price shall be as stated in
Paragraph 3 of the Agreement.
IN WITNESS WHEREOF, Seller has signed and delivered this instrument
on t he 1 rrr day of .dune, 20 0.
HSSG Sank Nevada, N.A.
Susan: So >ornon
Seri :tor dice President
I£�iffi(_ �':zrrt ssu� L2�:E:3il�l't'icec
1 i 1 •rA M , 1'M ('enter 03 *` , U& c, zg;a ; N V S.9 i =4
EXH BIT A (Continued,
ASSIGNMENT AND BILL OF SALE
HSBC Receivables A cq union Corporat ( USA ) !V, (herein -after called
"Seller") has entered into an Account Purchase and Sale Agreement as of
Febr uary 1 2010 CAgreem a s amended for the sale of Charged Off
Receivables described in Paragraph 1 thereof to Sherman Originator III, LLC
'hereinafter called "Purohas€;r "), upon the terms and conditio ns set forth in that
Agreement.
NOM THEREFORE, for good and valuable coll"sideration Seiler hereby
sells, a ssigns : and tra nsfers to Purchaser, its successors and assigns, all of
Seller's tights, title, and interest in each and evenj one of the Charged Off
Receivables described in the Agreement and is Exhibit A attached hereto.
Purchaser and Seller agnee that the Purc Price shall be as stated in
Paragraph 3 of the Agreement.
IN W11'NES5 WHEREOF, Seller has signed and delivered this instrument
on the 'i day of June 2010,
HSSC Receivables Acquisition
Corporation (USA) IV
Susan Solomon
Vkx- Prosidont
t�SE3f: F,;fJIfE &tx! �.Ett2FF �Q;rY1CYR
1. ;p) C:a'riier TSrjv,', Eras NV 89 144
Declaration of Account Transfer
Sherman Originator III LLC ( "SOLLC III "), without recourse, to the extent permitted by
applicable law, transferred, sold, assigned, conveyed, granted and delivered to Sherman
Originator LLC ( "SOLLC ") all of its right, title and interest in and to the receivables and other
assets (the "Assets ") identified on Exhibit A, in the Receivable File dated June 10, 2010
delivered by HSBC Bank Nevada, N.A. and HSBC Receivables Acquisition Corporatioon ( USA
) IV on June 15, 2010 for purchase by SOLLC III on June 15, 2010. The transfer of the Assets
included electronically stored business records.
SOLLC, subsequent to the above mentioned transfer, transferred, sold, assigned, conveyed,
granted and delivered to LVNV Funding LLC ( "LVNV "), the above mentioned Assets. The
transfer of the Assets included electronically stored business records.
Sherman Originator III LLC
a Delaware Limited Liability C.btnpany
B
Nan�4: Jon �4.az >
Title: Diractnr
Shem an Originator I I,C
a Delawaxe Limited Liability Company
BY: d� .
am..: evi ranigan
Title: Auth&lzed RepresentativO
lArNV Funding LLC
a IDehrore Lunited Liability Company
Name: Les Gutiertez -
"iitle:. Authorized Representative
Exhibit A
Receivables File
06.15.10
Transfer Group Portfolio Transfer Batch
159986 14857 N/A
k
• Yamaha Account Statement
Account Number 0176 -631= 893
• Page 1 of 2 From April 12, 2010 to
Previous Balance $4,379.50 Now Balance $4,495.96
Payments - $0.00 Minimum Payment Due $1,247.00
Other Credits - $0.00 Payment Due Date June 4, 2010
Purcbases/Debits + $0.00
Past Due Amount $1,085.00 Late Payment Warning: If we do not receive your minimum payment by the
Fees Charged + $39.00 date listed above, you may have to pay a late fee of up to $39.00 and your
Interest Charged + $77.46 APRs may be increased to the Penalty APR of24.99 %.
New Balance $4,495.96
Minimum Payment Warning: If you make only the minimum payment each
Credit Limit $0.00 period, you will pay more in interest and it will take you longer to pay offyour
Credit Available $0.00 balance. For example:
Statement Closing Date May 12, 2010
Days in Billing Cycle 31
If you make no additional You will pay off the And you will end up
charges using this card balance shown on this paying an estimated
and each month you statement in about.. total of...
pay...
Only the minimum 20 Years $10,696
payment
$179 3 Years $6,434
(savings = $4,262 )
If you would like information about credit counseling services, call
1- 866 -569 -2227.
Questions? Payment Address: HSBC Retail Services, PO Box 17602, Baltimore MD,
Customer Service 1 -800- 365 -0492 21297 -1602
TDD/Hearing Impaired 1 -800- 365 -0186 Billing Inquiries: Retail Services, PO Box 15521, Wilmington DE,
19850 -5521
Manage Your account online at www .Yamaha - motor.com /cardaccount
As a reminder, you may pay your credit card bill online or through our automated phone system for no fee.
Trans Date Post Date Description of Fees Reference Number Amount
05/04/10 05/04/10 LATE CHARGE ASSESSMENT Reg - Purch 10000000010504999572460 $39.00
Total Fees For This Period $39.00
Description of Interest Charge Amount
INTEREST CHARGE ON PURCHASES $77.46
Total Interest For This Period $77.46
Total fees charged in 2010 $117.00
Total interest charged in 2010 $288.16
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Demob and noun bottomponian with yom peyment 176631 S 11 0220 12859 See reverse side for hnportant womlation
------------------------------------------------------------------------------------------------------------------------------------------
Account Number. 0176 -0311 -0130 -1893
New Balance $4,495.96
Minimum Payment Due $1,247.00
Payment Due Date 06/04/2010
Include account number on check to HSBC Retail Services. Do not
send cash. Please send your payment 7 to 10 days prior to the
payment due date to ensure timely delivery.
176 AMOUNT
ENCLOSED
HSBC RETAIL SERVICES
CLIFFORD D BROWN JR PO BOX 17602
5200 E TRINDLE RD BALTIMORE MD 21297 -1602
{1 MECHANICSBURG PA 17050 -3570 IIIII�I���IIIIII��IIIf �I��IIIIIIIII�I�I��IIIIII��I��I�����IIIIIII
I II� I � I � I I�I� II I I ���� I I��I�I I � I �I�I III II�� II �� I I�I�III I II� II I�II I
00449596001247000000176631101301893001767
• - Yamaha Account Statement
Account Number 0176 - 6311 - 0130 -1893
Page 2 of 2 From April 12, 2010 to May 12, 2010
Type of Balance Annual Percentage Rate (APR) Balance Subject to Interest Rate Interest Charge
Regular Purchase 06402 -01 24.99% $3,325.23 $70.57
Regular Purchase 00088 -02 24.99% $324.85 $6.89
REGULAR PURCHASE 24.99% $0.00 $0.00
00002
v= Variable Rate
Credit Plan/Promotion Type Purchase Promotional Previous New Minimum Deferred Promotional Payoff
Date Expiration Date Balance Balance Payment Interest Amount
Regular Purchase 06402 -01 04/132006 N/A $4,069.21 $4,139.78 $890.82 $0.00 $4,139.78
Regular Purchase 00088 -02 05/042008 N/A $310.29 $356.18 $356.18 $0.00 $356.18
176631 S 11 0220 12859
___________________________________________________________________________________________________________ _______________________________
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PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service MUST BE FILED WITHIN TEN(10)DAYS AFTER filing of the notice of appeal. Check applicable boxes.)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND ; ss
AFFIDAVIT: I hereby(swear) (affirm)that I served
® a copy of the Notice of Appeal, Common Pleas No 13-7088 CIVIL, upon the Magisterial District Judge designated
therein on
(date of service) , 12/09, 2013, El by personal service ® by(certified) (registered) mail,
sender's receipt attached hereto,and upon the appellee, (name)Clifford Brown , on
12/09, 2013, El by personal service ® by(certified)(registered) mail,
sender's receipt attached hereto.
SWORN (AFFIRMED)AND SUBSCRIBED BEFORE ME
THIS 09 TH DAY OF December,2013
1/ r i
Signature of official before whom affidavit was made Signature • affiant
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AOPC 312A-05
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PS Form 3800.August 2006 See Reverse for Instructions
IN THE COURT OF COMMON PLEAS OF '
CUMBERLAND COUNTY,PENNSYLVANIA i
LVNV FUNDING LLC
YAMAHA-RBP TIER 3 : CIVIL ACTION r• i -E r'L ; 1 1 COL
PE SYLVAN!
Plaintiff :
r`5 - '7088
vs.
: NO'-�V-1764
Clifford Brown
Defendant .
CERTIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on December 13, 2013 the below
named Defendant received and signed for the certified mail containing the Plaintiff's Notice of
Appeal of the District Justice Judgment and Complaint.
Clifford Brown
407 5TH ST
EAST PENNSBORO PA 17025
Edwin A. Abrahamsen& Associates, P.C.
%ice/
BY:
Mic .el F. Ratchford, Esquire
Attorney I.D. No.: 86285
120 N Keyser Avenue
Scranton, PA 18504
(570) 558-5510
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
YAMAHA-RBP TIER 3 • CIVIL ACTION
Plaintiff :
vs.
: NO: CV-170-13
Clifford Brown
Defendant :
CERTIFICATE OF SERVICE
I, Michael F. Ratchford, Esquire, hereby certify that on December 13, 2013 the below
named District Justice received and signed for the certified mail containing the Plaintiffs Notice
of Appeal of the District Justice Judgment.
District Court 09-3-04
Honorable Paula P. Correal District Justice
5275 E Trindle Rd. Suite 110
Mechanicsburg, PA 17050
Edwin A. Abrahamsen &Associates, P.C.
B/ — t
ichael F. •atchford, E.quire
Attorney I.D.No.: 862:5
120 N Keyser Avenue
Scranton, PA 18504
(570) 558-5510
•
SENDER Cv.;PLETE THIS`,t T/t)t rll'LL IL 1HIS SECTION ON DELIVERY
• Complete items 1,2,and 3.Also complete
Item 4 if Restricted Delivery is desired. / / Fe.A.4 Agent
■ Print your name and address on the reverse ,, Addressee
so that we can return the card to you. --by(Printed Name) C. Date of Delivery
• Attach this card to the back of the mailplece, _ /
or on the front if space permits.
D. Is delivery address different from item 1? ❑Yes
1. Article Addressed to: If YES,enter delivery address below: ❑No
/11/a%_09— S-°4I
o 3. Se re a Type
Mertified Mall 0 Al j2Q 9 /76
❑Inegsulrestd ereMd all ❑D CRe.O.Dr.R
Receipt for Merchandise
-9)1 ;t02-/_
2 4. Restricted Delivery?(Extra Fee) ❑Yes
2. Articb NLIMber 1 1 1 i 1 ¢
(Transfer from service/abed 7 012 2 210 0000 610 0 4989
PS Form 3811,February 2004 Domestic Return Receipt 102595-02-M-1540;
ry 1
SE'lt - R CC)Il i If 71- 7■ I<, r rx,r;
• Complete items 1,2,and 3.Also complete A. Signature /
Item 4 if Restricted Delivery is desired. t
• Print your name and address on the reverse X C
so that we can return the card to you.
• Attach this card to the back of the mailplece, B. Received y Addreseee fri Printed Name) /C. Date of Delivery on the front if space permits. Ch.166/ 01 1 Z��oy13
1. Article Addressed to: D. Is delivery address different from Item 1? Y
,� M If YES,enter delivery address below: ❑No
/pup l,- - � - -
TUi 5' i,� prl=u ; to
c.XL0-10-i Pi /l Ua 3 3. Srytice Type
Certified Mall ❑Express Mail
❑Registered ❑Return Receipt for Merchandise
❑Insured Mall ❑C.O.D.
9.\\ .../.)&121 4. Restricted Delivery?(Extra Fee) ❑Yes
2. Article Number,it ai
Mender '' 7012 2210 0000 6100 4996
PS Form 3811,February 2004 Domestic Return Receipt 102595-02-A1-1540;
I
LVNV FUNDING LLC
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Plaintiff Civil Division
VS.
NO: 13-7088 CIVIL
Clifford Brown ; Praecipe to Defer/Suggestion of Bankruptcy
Defendant
I�M,4
To the Prothonotary of CUMBERLAND County Pennsylvania: '
rte`
Please enter the above Praecipe to Defer/Suggestion of Bankruptcy. car-
-.
AhanK
7
—� 4
r"D
atchford, squire
Edwin A. Abraham n &Associates,P.C.
Lawyer ID# 8628
120 N.Keyser A enue
Scranton, PA 18 04
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
LVNV FUNDING LLC
Plaintiff : CIVIL DIVISION
VS. NO: 13-7088 CIVIL
Clifford Brown
Defendant
CERTIFICATE OF SERVICE
1, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served
a copy of the Praecipe to Defer/Suggestion of Bankruptcy in the above captioned matter by mailing
the same via First Class United States mail, postage prepaid addressed as follows:
JAMES M. BACH, ESQ.
352 SOUTH SPORTING HILL RD
MECHANICSBURG PA 17050
Edwin A. Abrahamsen& Associates, P.C.
Date: February 14, 2014 By.
Michael F. Ratchforue squire
Attorney I.D. No.:
120 N. Keyser Ave
Scranton, PA 1850
(570) 558-5510