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LVNV FUNDING LLC In the Court of Common Pleas of
55 Beattie Place Suite 110 CUMBERLAND County, Pennsylvania
Greenville, SC 29601 Civil Division
Plaintiff
NO: 14 & 1vi l - T erw
vs.
Barbara Coons
651 COLDSPRING RD PRAECIPE FOR ENTRY OF JUDGMENT
FAYETTEVILLE PA 17222 -9755
Defendant
To the Prothonotary of CUMBERLAND County:
1) Enter Judgment on the attached Exemplified Record of Judgment from FRANKLIN .
County. --'
M
A) Date of Instrument: February 27, 2013
U. r
13 Amount of Judgment: $1,506.09
C) Interest From: February 27, 2013 �' 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
55 Beattie Place Suite 110
Greenville, SC 29601
4) 1 hereby certify that the address of the defendant is:
Barbara Coons
651 COLDSPRING RD
FAYETTEVILLE PA 17222 -9755
4icha.rd, Esquir Attorne for Plaintiff
Michael F. Ratchford, Esquire 4 -3 3 . 50 P u p
Edwin A. Abrahamsen & Associates, P.C.
120 N. Keyser Ave e 0gr1%a
Scranton, PA 18504 P3 3(c)-3*8
570 -558 -5510 Ext. 101
Attorney ID 86285
COMMONWEALTH OF PENNSYLVANIA,
COUNTY OF FRANKLIN SS.
Deanna F Hartman 1st Deputy
I, kkKkvkxfkayd; PrZonotary of the Court of Common Pleas in and for
said County, do hereby certify that the foregoing is a full, true and correct copy
of the whole record of the case therein stated, wherein......... L jTL Fund ing LLC
.................................................................................................. ...............................
Plaintiff, and .... F q- ba Pns
.................................................. ...............................
.................................................................................................. ...............................
Defendant, so full and entire as the same remains of record before the said Court, as No. 2013-.811..
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of said Court, this
14th „Day„ of „July - -„ 2014....
V. ....... . ......... .... .......
1st Deputy Prothonotary
I Douglas W. Herman .............................. President Judge of the Court of Common Pleas
of the 39th Judicial District, Franklin County Branch, do certify that Linda L. Beard, Prothonotary,
by whom the annexed record, certificate and attestation were made and given, and who, in her own
proper handwriting, thereunto subscribed her name and affixed the seal of the Court of Common Pleas
of said County, was at the time of so doing and now is Prothonotary in and for said County in the
Commonwealth of Pennsylvania, duly commissioned and qualified; to all of whose acts, as such, full
faith and credit are and ought to be given, as well in Courts of Judicature as elsewhere, and that the
said record, certificate and attestation are in due form of law and made by t e proper officer.
President Judge
COMMONWEALTH OF PENNSYLVANIA,
COUNTY OF FRANKLIN SS.
1, � ea n F Har n, 1st Depu
Xx prothonotary oMe Court of Common Pleas of the 39th Judicial District,
Franklin County Branch, do hereby certify that the Honorable....... Douglas Herman ....................
by whom the foregoing attestation was made, and who has hereunto subscribed his name, was at the
time of making thereof and still is President Judge of the Court of Common Pleas, in and for said
County, duly commissioned and qualified; to all whose acts, as such, full faith and credit are and ought
to be given, as well in Courts of Judiciature as elsewhere.
IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the
seal of said Court, this ................... day of ....... July . A.D. 20.
.. ...................... ........
lst Deputy Prothonotary
r
Among toe i4efIIrbs anb praccebingS enrolled in the Court of Common Pleas in and for the
County of Franklin in the Commonwealth of Pennsylvania, to No ................ . ..... ................,
is contained the following:
COPY OF ............... 2013- 87 ,1.,,,.,,,,,.,,.,,,.,.,,,..,.,, DOCKET ENTRY
LVNV FUNDING LLC
Plaintiff
VS.
SEE ATTACHED
BARBARA COONS
Defendant:
PYS511 Franklin County Prothonotary's Office Page 4 1
Civil Case Print
X013 -00871 LVNV FUNDING LLC (vs) BARBARA COONS
Reference No... Filed......... 2/28/2013
Case Type.....: DISTRICT JUST JUDGMENT Time.........: 1:18
Judgment..... 1,506.09 Execution Date 0 /00 /0000
Judge Assigned: Jury Trial....
Disposed Desc.: Disposed Date. 0 /00 /0000
------ - - - - -- Case Comments ------- - - - - -- Higher Crt 1.:
Higher Crt 2.:
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
General Index Attorney Info
LVNV FUNDING LLC PLAINTIFF RATCHFORD MICHAEL F
15 SOUTH MAIN STREET
GREENVILLE SC 29601
COONS BARBARA DEFENDANT
651 COLDSPRING ROAD
FAYETTEVILLE PA 17222 9755
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
Judgment Index Amount Date Desc
COONS BARBARA 1,506.09 2/27/2013 JUDGMENT
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
* Date Entries
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
- - - - - - - - - - - - - FIRST ENTRY - - - - - - - - - - - - - -
2/27/2013 PRAECIPE FOR ENTRY OF JUDGMENT ENTERING IN FAVOR OF THE PLAINTIFF
AND AGAINST THE DEFENDANT IN THE AMOUNT OF $1,506.09 WITH AFFIDAVIT
UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS
AMENDED FILED AND COPY RETURNED TO ATTY.
-------------------------------------------------------------------
2/27/2013 NOTICE OF ENTRY OF JUDGMENT SENT VIA REGULAR MAIL TO DEFENDANT(S).
-------------------------------------------------------------------
7/14/2014 REQUEST FOR EXEMPLIFIED RECORD OF JUDGMENT FILED.
EXEMPLIFIED RECORD PREPARED AND RETURNED TO ATTY RATCHFORD.
- - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - -
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
* Escrow Information
* Fees & Debits Bw * Bal * * * mts /Adl End Bal
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * ** * * * P * * * * ** * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
JUDG D.J. 17.00 17.00 .00
JUDG D.J. DISC 5.00 5.00 .00
JUDG D.J. .25 .25 .00
DJ JDG -AUTO FEE 5.00 5.00 .00
EXEMPLIFICATION 21.00 21.00 .00
------------------ - - - - -- ------ - - - - --
48.25 48.25 .00
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
* End of Case Information
I W-212A M & mlwt-
************************************************* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * **
LINDA L. B ARD, TRO HO TARY
lT'dv .
I.VNV FUNDING L,I..0 In the Court of Common Pleas of
15 South Main Street I- RANKLIN County, Pennsylvania
Greenville, SC 29601 Civil Division
Plaintiff
NO: 1
vs.
Barbara Coons
651 COLDSPRING RD PRAECIPE FOR ENTRY OF JUDGMENT
FAYETTEVILLE PA 17222 -9755
Defendant
To the Prothonotary of FRANKLIN County:
1) Enter Judgment on the attached Certified copy of Judgment from a District Justice.
A) Date of Instrument: March 6, 2012
B) Amount of Judgment: $1,506.09
C) Interest From: March 6, 2012
2) Enter the judgment in favor of the plaintiff; `-;
3) 1 hereby certify that the address of the plaintiff is:
LVNV FUNDING LLC or,_
15 South Main Street
Greenville, SC 29601
co
4) 1 hereby certify that the address of the defendant is:
Barbara Coons
651 COLDSPRING RD
FAYET'1'EVILLE PA 17222 -9755
Mich I F. R!6 hford, Esquire Attome for Plaintiff
Michael F. Ratchford, Esq e ,
Edwin A. Abrahamsen & ssociates, P.C.
120 N. Keyser Ave
Scranton, PA 18504
800 - 503 -1665 Ext. 101
Attorney ID 86285
ATTEST A TRUE COPY
LINDA L. B Raj, FROTfIONOTARY
LVN V FUNDING LLC In the Court of Common Pleas of
15 South Main Street FRANKLIN County, Pennsylvania
Greenville. SC 29601 Civil Division
Plaintiff
NO: �`��l
vs.
Barbara Coons
651 COLDSPRING RD AFFIDAVIT UNDER SOLDIERS AND SAILORS
FAYET'1'EVILLE PA 17222 -9755 RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED
Defendant
" o
State of Pennsylvania:=
County of FRANKLIN SS:
Michael F. Ratchford, Esquire being duly sworn according to law deposes and says Viat the above
named defendant(s): Barbara Coons is(are) not in the military service of the United Mates of
America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended;
That the defendant(s): Barbara Coons is(arc) older than eighteen years of age;
That the employment status of the defendant(s): Barbara Coons is(are) unknown.
Wicliail F. Ratchf d, Y,4quire
N
a of� 20 `
Subscribed before me this d y
Not ub c NWF4L7 OF PENNSYCyti,y;q
Dtanne seat
M Of Scram, wanna County I
MEfR PH INSy�VAnL4 AS A77
OF FNj
Judgment Detail I `PostJudgment)
In the matter of Lvnv Funding llc vs, Barbara Coons on 3106012 the judgment was awarded as follows:
Judgment Component JoinUSeveFal Liability I Livid I Liam De si Applied Ama n
Civil Judgment $0.00 $1,407.59 $1,407.59
Filing Fees $0.00 $98.50 $98.50
Grand Total: $1,508,09
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
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.
�nF
.r �+
3 Ir
MILK
Date Magisterial District Judge Todd R. Williams Jill
ce at th is a true and correct copy of the recor7 of the proceedings containing Me Judgment.
Date Magisterial District Judge
MDJS 315 Page 1 of 2 Printed: 101311201211 :37:40AM
Lvnv Funding Lic Docket No.: MJ- 39304 -CV- 0000029 -2012
V.
Barbara Coons
Participant List
Plaintiffs)
Lvnv Funding Llc
C/O Edwin A. Aabrahamsen
120 N. Keyser Ave.
Scranton, PA 18504
Defendant(s)
Barbara Coons
651 Coldspring Rd
Fayetteville, PA 17222
Complainant's Attorney(s)
Michael F. Ratchford, Esq.
Go Edwin A. Abrahamsen & Associates, P.C.
120 North Keyser Avenue
Scranton, PA 18504
MDJS 315 Page 2 of 2 Printed: 10/3112012 11:37:40AM
Department of Defense Manpower Data Center Resu!!saso►;feb222013CRA2.3
SCRA 2,3
Pursuanit to Smicemembo Civil Relief Act
Last Name COONS
First Name: BARBARA
Middle Name:
Active Duty Status As 01; Feb - 22.2013
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Upon searching the data banks of the Department of Defense ManpowerDBta,Center; based on the information that you provided, the above is the status of
the individual on the active duty status dale 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 Servicemember or hismer unit receiving notification of future arders to report for Active Duty,
A
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
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 AG (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any Information indicating 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 /faglpis /PC0gSLDR.html. 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, SSWdate of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: JISUIMLA18
651 COLDSPRING RD AFFIDAVIT UNDER SOLDIERS AND SAILORS
FAYETTEVILLE PA 17222 -9755 RELIEF CIVIL RELIEF ACT OF 1940 AS
Defendant AMENDED
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): Barbara Coons 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): Barbara Coons is(are) older than eighteen years of age;
That the employment status of the defendant(s): Barbara Coons is(are) unknown.
/Micha I F. Ratchford7squire
/
Subscribed before me this l day of 2f1
I%
/�
Notary Public
s :.
C
;.O X
I0T r`r)
LVNV FUNDING LLC
55 Beattie Place Suite 110 In the Court of Common Ple T JUL 1 I h � 2. 28
Greenville, SC 29601 FRANKLIN County, Pennsy vama
Plaintiff Civil Division
o
vs.
n.
NO: 2013 -871
Barbara Coons
651 COLDSPRING RD Request for Exemplified Record of Judgment
FAYETTEVILLE PA 17222 -9755
Defendant
To the Prothonotary of FRANKLIN County Pennsylvania:
Please enter this Request for Exemplified Record of Judgment to transfer the Judgment to
CUMBERLAND county.
Thank you,
ichael F. atchford, E uire
Edwin A. Abrahamsen Associates, P.C.
Lawyer ID # 86285
I L�
Sworn and subscribed before me on this ,, I day of 20
Notary Pu is
OOMMOiN%yc"ALTH OF PENNSY
ATTBST A TRULP COPY �:otanal Sea, LVANIA
A isa Nattern, Notary P�rt�•� l •��
j Ci °r c` Scran on I acka: anna col rry
1Y CCZ111 csion Expires t.
Scp 19, 2017 r
LIMPA BB R , PROTHOW;rARY = ss : 477 --r+c=
Department of Defense Manpower Data Center Results as of: Aug•21.201406 :34 :57 AM
SCRA 3.0
S wus Report
Pert to Smiccmembo Civil Relief Act
Last Name; COONS
First Name; BARBARA
Middle Name;
Active Duty Status As Of: Au -2g 1 -214
onA�ve Duty onActive sfaius Date
WveDuly start Date Active Duty End Date Status $eivioe Car�orrant
NA NA No ` NA
This response reNttheWlkluals'aciive duty stabs based on the AckOury Sits Date
left Adive Duly Wdhm 367 Days d AcNe 00 Status Date
kM D4SWDate Alive Duly End Dale 5tatuS Service Component
NA NA No ' NA
This response retlecis wherethe individual Id active dutyslatua On 367 days preceding the AdODuiy Status Date
The MemberorHisrHer Auras NAd da FutureCaIkUp bkUve D onkINe Du Slabs Date
Order Nofirrcab Start Date Order Nab End Dab sWo SeNioe Component
NA to No NA
r.
This response reflects whether a WMdual orhisiher unit has received ead nafton bT pori for act a duty
Upon searching the data banks of the Department of Defense Manpower Data Center, bash on the information th 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 Servicemember or hislher unit receiving notification of future orders to report for Active Duty.
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
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 Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly known as
the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating 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: hftp: / /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 /date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Certificate ID: SCFC2B79Y056410
LVNV FUNDING LLC ; In the Court of Common Pleas of
55 Beattie Place Suite 110 CUMBERLAND County, Pennsylvania
Greenville, SC 29601 Civil Division
Plaintiff 0O 1
NO: 1 P�`Yh
vs.
Barbara Coons NOTICE OF FILING JUDGMENT
651 COLDSPRING RD
FAYETTEVILLE PA 17222 -9755
Defendant
Notice is herby given that a money judgment in the above - captioned matter has been entered
against you in the amount of $ �p( , eq on �R�Ir�
By: .�
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)
120 N KEYSER AVE SCRANTON, P418504 (P) 570.558.5510 (F) 570.558.5511
LVNV FUNDING LLC
vs.
Barbara Coons
651 COLDSPRING RD
FAYETTEVILLE PA 17222-9755
VS.
METRO BANK
3201 TRINDLE RD
CAMP HILL, PA 17011
ORRSTOWN BANK
3045 MARKET ST
CAMP HILL, PA 17011
In the Court of Common Pleas of
Plaintiff : CUMBERLAND County, Pennsylvania
: Civil Division
: NO: 14-5061
Defendant :
Garnishee
Praecipe for Entry of Appearance
Kindly enter my appearance on behalf of LVNV FUNDING LLC in the above -captioned matter.
Date:September 15, 2014
Signature:
Print Nam
Address:
Ai(
Michael
Ratchford Es
u
e
20 North Ke ser Avenue
Scranton PA 18504
Telephone No: (570) 558-5510 Ext. 120
Supreme Court ID No: 86285
PRAECIPE FOR WRIT OF EXECUTION — (MONEY JUDGMENT) RULES PA. R.C.P. 3252,311.1 (a)
LVNV FUNDING LLC
vs.
Barbara Coons
651 COLDSPRING RD
FAYETTEVILLE PA 17222-9755 ern "rt
d�
,;7 cT —iC
T OF EXECUTIONy`AO
•
Plaintiff :
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
C")
d
G
r•
szP-
vs.
NO: 14-5061
Defendant .
METRO BANK
3201 TRINDLE RD PRAECIPE FOR
CAMP HILL, PA 17011 ATTACHMENT
ORRSTOWN BANK
3045 MARKET ST
CAMP HILL, PA 17011
Garnishee
(MONEY JUDGMENT)
cy
To the Prothonotary: TO SATISFY THE JUDGMENT, ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania;
(2) Against: Barbara Coons
(3) And against: METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 And ORRSTOWN BANK
3045 MARKET ST CAMP HILL, PA 17011
(4) and index this writ (a) against
Defendant(s) (b) against METRO BANK 3201 TRINDLE RD CAMP HILL, PA 17011 and ORRSTOWN
BANK 3045 MARKET ST CAMP HILL, PA 17011Garnishee(s),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(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):
***-**-9409;
(5)
Date: September 15, 2014
Judgment Amount
Interest
Payments
Clerks Fee
Sheriff
Poundage
Total
I Qa. d a
tiVd-
.,RS C 3F
33. SO " 'I
B9,1s
$1,506.09
$139.89
Michae- F. ' . 'hford, Esquire
Edwin A. A:rahamsen & Associate., P.C.
Attorney for Plaintiff
mratchford@eaa-law.com
rn� PI Ailito
154', 5D LL -
1 cr 6€‘ _Ar,d
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 14-5061 Civil Term
CIVIL ACTION — LAW
BARBARA COONS
WRIT OF EXECUTION
(Pa R.C.P. 3252)
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against BARBARA COONS, 651 COLDSPRING ROAD,
FAYETTLEVILLE, 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
METRO BANKGARNISHEE(S), as garnishee, 3201 TRINDLE ROAD, CAMP HILL, PA 17011 AND
ORRSTOWN BANK , 3045 MARKET STREET, CAMP HILL, PA 17011 - 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. (Specifically
describe 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.
1
(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
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 $1,506.09
Interest $139.89
Attorney's Comm. %
Attorney Paid $89.75
Date: 10/L0 tG
(Seal)
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
-124.c.;za 1,twet
David D. Buell, Prothonotary.
REQUESTINGPARTY:
Name : MICHAEL R. RATCHFORD, ESQUIRE
Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C.
120 N. KEYSER AVENUE
SCRANTON, PA 18504
Attorney for: PLAINTIFF
Telephone: 570-558-5510
Supreme Court ID No.
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
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
01
at
‘c''‘
.?1,6
QFP LE
QF TNE $RERIFP
F;LED-OFF10E
Or THE PROTHONOTARY
10114 OCT 10 PN i: 12
CUMBERLAND COUNTY
PENNSYLVANIA
LVNV Funding LLC
vs.
Barbara Coons
Case Number
2014-5061
SHERIFF'S RETURN OF SERVICE
10/09/2014 11:17 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, Orrstown Bank, 22 South Hanover Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Chastity Bucher, Head Teller, personally three copies of
interrogatories together with three true and attested copies of the Writ of Execution an ade the contents
there of known to her.
L IA CLINE, DEPU
SO ANSWERS,
October 09, 2014 RONNY R ANDERSON, SHERIFF
(c> CountySuite Sheriff, Teleosoft,
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
HOF—C
—
ot Cum OF Thr PROTHONOTARY
20140CT 10 NM l: 2
„' -^
— '�—
���� COUNTY
PENNSYLVANIA
LVNV Funding LLC
vs.
Barbara Coons
Case Numbe
2014-5061
SHERIFF'S RETURN OF SERVICE
10/09/2014 11:23 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, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Nicole Erickson, Store 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 October 9, 2014 to Baara a Coons at 651
Coldspring Road, Fayetteville, PA 17222.
WILLIAM CLINE, DEPUTY
SO ANSWERS,
October 09, 2014 RON R ANDERSON, SHERIFF
(c) CountySuite Sheriff: Teleosoft. Inc.
M
LVNV FUNDING LLC
vs.
Barbara Coons
65 ]. COLDSPRING RD
FAYETTEVILLE PA 17222-9755
vs.
METRO BANK
3201 TRINDLE RD
CAMP HILL, PA 17011
ORR:STOWN BANK'
3045 MARKET ST
CAMP HILL, PA 17011
In the Court of Common Pleas of
Plaintiff . CUMBERLAND County, Pennsylvania nn
Civil Division to
Defendant .
Garnishee
NO: 14-5061
INTERROGATORIES IN ATTACHMENT
23.. (:43
RE: Execution of Judgment against your depositor Barbara Coons SSN # ***-**-9409
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.
Defendant has account with a balance of $.81
Account is also listed as joint entities
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?
xxxxxx8158 balance $.81
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.
$61.89
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?
no
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?
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 the Depositor's direction
or otherwise discharge any claim of the Depositor against you?
no
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)?
no
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.
no
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.
yes
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.
see answer to question 1
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).
Edwin A. - . aha ' sen
By
Mic ael F. Ratchfor: Esquire
120 North Keyser venue
Scranton, PA 18514
(570) 558-5510 E t. 101
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 Jennifer Hilbish
Levy Specialist
(Title)
(Name)
of Metro Bank, garnishee herein,
(Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/ erknowledge, information and
belief.
LVNV FUNDING LLC
: In the Court of Common Pleas of
Plaintiff : CUMBERLAND County, Pennsylvania
: Civil Division
vs.
Barbara Coons
651 COLDSPR1NG RD : NO: 14-5061
FAYETTEVILLE PA 17222-9755
Defendant
Praecipe to Dissolve the Attachment against
vs. : Garnishee
ORRSTOWN BANK
3045 MARKET ST
CAMP HILL, PA 17011
Garnishee
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
chael F. Ratchfo Esquire
Abrahamsen Ratch rd, P.C.
Lawyer ID # 86285
C.)
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LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff : CUMBERLAND County, Pennsylvania
. Civil Division
vs.
Barbara Coons
651 COLDSPRING RD
FAYETTEVILLE PA 17222-9755
Defendant
vs.
METRO BANK
3201 TRINDLE RD
CAMP HILL, PA 17011
: NO: 14-5061
•
Praecipe to Dissolve the Attachment dga'ih'st
•
Garnishee
Garnishee .
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Dissolve the Attachment against Garnishee.
Thank you,
ichael . Ratchford, ' squire
Abrahamsen Ratchfor , P.C.
Lawyer ID # 86285
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