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HomeMy WebLinkAbout11-6761 EQUABLE ASCENT FINANCIAL LLC c/o Edwin A. Abrahamsen & Assoc. 120 North Keyser Ave. Scranton, PA 18504 VS. Plaintiff . TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant To the Prothonotary of CUMBERLAND County: In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division M NO:? \r vc?l ???';L rn wZ ? PRAECIPE FOR ENTRY OF JUDGMEN a =q AC= twa !V 0-% y7? 1) Enter Judgment on the attached Certified copy of Judgment from a District Justice. A) Date of Instrument: February 4, 2011 B) Amount of Judgment: $2,360.14 C) Interest From: February 4, 2011 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: EQUABLE ASCENT FINANCIAL 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: TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 F Michael F. Ratchford, Esquire Edwin A. Abrahamsen & Associates, P.C. r 120 N. Keyser Ave Scranton, PA 18504 570-558-5510 Ext. 101 Attorney ID 86285 G> ? _.q Cy C?7M Esquire Attom# for Plaintiff i OLM IL a7.9 sped a 1h? Ck 44 at ssa 1?-* Qu s v) lP EQUABLE ASCENT FINANCIAL LLC vs. Plaintiff TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: I l- W? lI l (?i V i NOTICE OF FILING JUDGMENT Notice is herby given that a money judgment in the above-captioned matter has een entered against you in the amount of $ on ?fl 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) EQUABLE ASCENT FINANCIAL LLC c/o Edwin A. Abrahamsen & Assoc. 120 North Keyser Ave. Scranton, PA 18504 Plaintiff VS. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant NO: AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS 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): TARA MOSEL 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): TARA MOSEL is(are) older than eighteen years of age; That the employment status of the defendant(s): TARA MOSEL is(are) unknown. 1 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division Michael . Ratchford, Subscribed before me this day of 414/ 20-L otary Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ-09-1-01 MDJ Name: Honorable Charles A. Clement Jr. Address: Olde Towne Commons 400 Bridge Street, Suite 3 New Cumberland, PA 17070 Telephone: 717-774-5989 Equable Ascemt Financial LLC c/o Edwin A. Abrahamsen & Assoc., P.C. 120 North Keyser Avenue Scranton, PA 18504 Disposition Summary Docket No MJ-091 01 -CV-0000668-201 0 Judgment Summary Participant Tara Mosel $0.00 $2,360.14 Equable Ascemt Financial LLC V. Tara Mosel Docket No: MJ-09101-CV-0000668-2010 Case Filed: 12/15/2010 Disposition Disposition Date Default Judgment for Plaintiff 02/04/2011 Amount $2,360.14 Judgment Detail ('Post Judgment) In the matter of Equable Ascemt Financial LLC vs. Tara Mosel on 2/04/2011 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $2,249.89 $2,249.89 Costs $0.00 $110.25 $110.25 Grand Total: $2,360.14 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSGRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. ad t ?, 2/4/2011 Date Magisterial District Judge Charles A. Clement Jr.„-$ I certify that this is a true and correct copy of the record of the proceedings i 6/20/2011 - e&nA? Date Magisterial District Judge Charles A. Clement 4fll MDJS 315 Page 1 of 1 Printed: 02/07/2011 3:09:03PM IV/v/?y Plaintiff Defendant Equable Ascemt Financial LLC Tara Mosel Joint/Several Liability Individual Liability i° iLEO-OFFICi i ;'HE PROTHONOTAR 2011 AUG 26 AM I I ; 40 CUMBERLAND COUNTY PENNSYLVANIA Request for Military Status Department of Defense Manpower Data Center 41 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of? Aug-23-2011 12:41:44 Last First/Middle Begin Date Active Duty Status Active Duty End Date Service ency A Name g Based on the information you have furnished, the DMDC does not possess MOSEL TARA any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Aftt M. 4"?_ D4?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Service Members Civil Relief Act (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 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 is on active duty, 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.html. If you have evidence the person is on active duty 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). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 8/23/2011 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days 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 TARs, Marine Corps ARs and Coast Guard 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) for a period of more than 30 consecutive days. 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. 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 SCRA extend beyond the last dates of active duty. Those who would 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 name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:66NATSENN2 https://www.dmdc.osd.mil/appj/scra/popreport.do 8/23/2011 r EQUABLE ASCENT FINANCIAL LLC 1804 WASHINGTON BLVD. Baltimore MD 21230 Plaintiff vs. : TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant vs. METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 P.? m rn -a-;-J -< C.0 Garnishee In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: 11-6761 CIVIL Praecipe for Entry of Appearance Kindly enter my appearance on behalf of EQUABLE ASCENT FINANCIAL LLC in the above- captioned matter. Date: April 25, 2012 Signaty?e: _ Print Name: Telephone No: (570) 558-5510 Ext. 101 Supreme Court ID No: 86285 PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a) EQUABLE ASCENT FINANCIAL LLC 1804 WASHINGTON BLVD. Baltimore MD 21230 VS. Plaintiff TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant vs. METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 Garnishee (MONEY JUDGMENT) 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: TARA MOSEL (3) And against: METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 (4) and index this writ (a) against Defendant(s) (b) against METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 Garnishee(s), as a lis 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): 162-54-2994; a (5) Judgment Amount Interest Payments Clerks Fee Sheriff Poundage In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division rn 00 ?... Z7n NO: 11-6761 CIVIL C PRAECIPE FOR WRIT OF EXECUTIO N AND ATTACHMENT $2,360.14 24.05 $611.90 Total $- O Date: April 25, 2012 *aC10D Po clq.a5 cE Michaq F. Ratchford, E: Edwin A. Abrahamsen & Attorney for Plaintiff elf4 l o *a.a,5 bw Ca 01??5aa3 .50 LL writ e? 3?()• I o i P.C. EQUABLE ASCENT FINANCIAL LLC 1804 WASHINGTON BLVD. Baltimore MD 21230 vs. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Plaintiff Civil Division TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant vs. METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 Garnishee NO: 11-6761 CIVIL AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS 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): TARA MOSEL; 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): TARA MOSEL; is(are) older than eighteen years of age; That the employment status of the defendant(s): TA Subscribed before me this day of 20 Notary Public Results as of : May-14-2012 06:46:31 Department of Defense Manpower Data Center SCRA 2.1 Status Report Pursuant to Serv cemembers Civil Relief Act Last Name: MOSEL First Name: Active Duty Status Date May-14-2012 Active Duty End Date Status Service cornpooeot On Active Duty On Attire Duty Status Date NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Dale Left Active Duty VirM11'rn 367 Days of Active Duty Status Date NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Mernbei or H./Her Urid Was NWmd of a Future CaN-Up to Active Duty on Active Duty Status Date NA No NA This response reflects whether the individual or his/her unit has received early notification 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 Servicemember or his/her unit receiving notification of future orders to report for Active Duty. A 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 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 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/faq/pis/PC09SLDR.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 maybe invoked against you. See 50 USC App. § 521(c). If you obtain additional information about the person (e.g., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual leftActive 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: J6QDQRNS4A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-6761 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due EQUABLE ASCENT FINANCIAL LLC, Plaintiff (s) From TARA MOSEL, 803 Rosemont Avenue, New Cumberland, PA 17070-0522 (1) 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: METRO BANK, 1130 Carlisle Rd, Camp Hill, PA 17011 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, (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 $1,748.24 L.L. $.50 Interest -- $24.05 Atty's Comm % Atty Paid $58.75 Plaintiff Paid Due Prothy $2.25 Other Costs Date: 5/15/12 (Seal) 1 JAA 1.!/?I?? ? j David D. Buell, Prothonotary 1P Deputy REQUESTING PARTY: Name : MICHAEL F. RATCHFORD, ESQUIRE Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, PC 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTIFF Telephone: 570-558-5510 Supreme Court ID No. 86285 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff b 1a..tji a Jody S Smith Chief Deputy Richard W Stewart Solicitor Equable Ascent Financial LLC vs. Tara L. Mosel 2012 MAY 18 PM I : 12 "UMBERL 444 COUNTY PENNSYLVANIA Case Number 2011-6761 SHERIFF'S RETURN OF SERVICE 05/17/2012 02:02 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 17, 2012 at 1402 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Tara Mosel, in the hands, possession, or control of the within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Greg Apgar, Customer Service Representative 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 him. The writ of execution and notice to defendant was mailed on May 18, 2012 to Tara Mosel, 803 Rosemont Avenue, New Cumberland, PA 17070. SO ANSWERS, May 18, 2012 RON R ANDERSON, SHERIFF Noah Cline, Deputy EQUABLE ASCENT FINANCIAL LLC 1804 WASHINGTON BLVD. Baltimore MD 21230 vs. Plaintiff TARA NIOSI-L 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant V S. METRO BANK 1130 CARLISLE RD CAMP HILL. PA 17011 Garnishee In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division - f?. NO: 11-6761 CIVIL ?-?1?1StvCvS b ` ? J? INTERROGATORIES IN ATTACIJMF\ F RE: Execution of Judgnlent against your depositor TARA MOSEL SSN # 162-54-2994 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) an dthe primary account holder and if known whether joint account is entireties property. Defendant has one account listed as a joint spousal account 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? 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-Interrogatioriesf nu ribtT oriel) 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? 5) At anv 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? (i) 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? .') 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. 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. 11) To the extent-tliat you re above answefs 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 sane). Edwin Ar A Michael F. Ratchford, E uire 120 North Keyser Aven e Scranton, PA 18504 (570) 558-5510 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 _ (Name) Levy Specialist of Metro Bank, garnishee herein, (Title) (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/her knowledge, information and belief. (SIGN,, URE) ?J EQUABLE ASCENT FINANCIAL LLC f/k/a HILCO RECEIVABLES LLC Plaintiff vs. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant vs. METRO BANK 1130 CARLISLE RD CAMP HILL, PA 17011 Garnishee q c_ In the Court of Common Pleas of '' M ` CUMBERLAND County, Pennsylv Civil Division is NO: 11-6761 CIVIL Praecipe to Dissolve the Attachment against Garnishee To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, Edwin A. Abraham n & Associates, P.C. Lawyer ID # 86285 Sworn and subscribed 4before on thisLday o 20 jq.SopAA? blic et'1 7r0o9a cor?MOSVV+1€??5? r- ?t??a.;?1 rj?tar??I Seal- pyanr?e Ndotary Pub!!,, ? IN e74sdd?1C 11 C- U, t? City of ,cranC??r'c ,fires i? ip Mty Corm , ,t'a s ? _ h1EMFSER FEA EQUABLE ASCENT FINANCIAL LLC In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division vs. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 vs. WELLS FARGO 6416 CARLISLE PIKE STE 21.00 MECHANICSBURG, PA 17050 NEW CUMBERLAND FCU 6692 CALISLE PIKE MECHANICSBURG, PA 17070 : NO: 11-6761 CIVIL Defendant : Garnishee c.n 477 • c. C: Praecipe for Entry of Appearance Kindly enter my appearance on behalf of EQUABLE ASCENT FINANCIAL LLC in the above - captioned matter. Date:May 20, 2014 Signatu/ Print Address: 120 North Ke 'ser Avenue Scranton. PA 18504 e: Micha 1 . Ratchford E uire Telephone No: 570 558-5510 Ext. 120 Supreme Court ID No: 86285 PRAECIPE FOR WRIT OF EXECUTION — (MONEY JUDGMENT) RULES PA. R.C.P. 3252,3111 (a) EQUABLE ASCENT FINANCIAL LLC vs. In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 : NO: 11-6761 CIVIL Defendant : vs. WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG, PA 17050 NEW CUMBERLAND FCU 6692 CALISLE PIKE MECHANICSBURG, PA 17070 Garnishee : PRAECIPE FOR WRIT OF EXECUTION AND ATTACHMENT (MONEY JUDGMENT) CD Cil rri CD i_ 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: TARA MOSEL (3) And against: WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG, PA 17050 And NEW CUMBERLAND FCU 6692 CALISLE PIKE MECHANICSBURG, PA 17070 (4) and index this writ (a) against Defendant(s) (b) against WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG, PA 17050 and NEW CUMBERLAND FCU 6692 CALISLE PIKE MECHANICSBURG, PA 17070Garnishee(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): '-*'*-2994; (5) Date: May 20, 2014 Judgment Amount $2.360.14 Interest $.00 Payments $ Clerks Fee $ Sheriff $ Poundage $ Total $ lialAK41014 chae r i Ratchford, Esquir Edwin A. Abrahamsen & As ociates, P.C. Attorney for Plaintiff mratchford@eaa-law.com --3,4. co P,3 Amy 88:3t, CBF d`1 OS it ,Q. o0 Q. So 183 ►3 -PA Krryy 4o •aS Nee 0,151i a,to ti3r;+ \iumsc EQUABLE ASCENT FINANCIAL LLC In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division vs. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 Defendant vs. : NO: 11-6761 CIVIL AFFIDAVIT UNDER SOLDIERS AND SAILORS WELLS FARGO RELIEF CIVIL RELIEF ACT OF 1940 AS 6416 CARLISLE PIKE STE 2100 AMENDED MECHANICSBURG, PA 170.50 NEW CUMBERLAND FCU 6692 CALL SLE PIKE MECHANI:CSBURG, PA 17070 Garnishee State of Pennsylvania County of CUMBERLAND: Michael. F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): TARA MOSEL; 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): TARA MOSEL; is(are) older than eighteen years of age; That the employment status of the defendant(s): TARA tic . f F. Ratchford. Esquire Subscribed before me this P day of Notary Public 20 COMMONWEALTH OF PENNSYLVANIA Notaral Seal Afisa Mattern, Notary City or Scranton, Lackawan Pablic Expires Sept.y Commission Cou0ty "eruea. 19, 2017 cY6YLVPi;A ASS3C14TICfi CF GG7ArC:S Department of Defense Manpower Data Center Results as of : May -27-2014 07:27:50 AM SCRA 3.0 Status Report Pursuant to Ser icemen Civil. Relief Act. Last Name: MOSEL First Name: TARA Middle Name: Active Duty Status As Of: May -27-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA6. '- ----- - . : i No i ' NA This response reflectsihe in tMduals' active duty status based on the Active Duty Status Date 7111` 5 .+ Left Active Duty Within 367 Da of Active Duty Status Date Active Duty Stan Dale Active Duty End Date I Status Service Component NA J " NA , , .N . 7t. '• rq 'ti No .. _ _ NA This response reflects where the individual left activeduty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Nofrfication Start Date Order Notification End Date Status Service Component NA \;,14A ".- �•.. - -s ti- f ::*;"c .No :.*i.; ! NA This response reflects whetherthe iridividual or hislher.unit has racefved eaty lotifcatiorito report for active duty t3i.f•f�.. f�� -sir' 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 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 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 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/faq/pis/PC09SLDR.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, 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: IAO1 X6A1 G0A0Q70 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 EQUABLE ASCENT FINANCIAL LLC Vs. NO 11-6761 Civil Term CIVIL ACTION — LAW TARA MORSEL WRIT OF EXECUTION (Pa R.C.P. 3252) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against TARA MORSEL, 803 ROSEMONT AVENUE, NEW CUMBERLAND, PA 17070 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 WELLS FARGOGARNISHEE(S), as garnishee, 6416 CARLISLE PIKE, SUITE 2100, MECHANICSBURG, PA 17050, AND NEW CUMBERLAND FCU, 6692 CARLISLE PIKE, MECHANICSBURG, PA 17070 - ANY AND ALL ACCOUNTS OF THE DEFENDANT(S), IN THE POSSESSION OF GARNISHEE, INCLUDING BUT NOT LIMITED TO SAVINGS ACCOUNT BALANCES; CHECKING ACCOUNT BALANCES; CERTIFICATE 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 $2,360.14 Plaintiff Paid Interest Law Library Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $1&3.13 Date: 5/30/14 (Sca I) bPare b-au.ELL. David D. Buell, Prothonotary REQUESTING PARTY: Name : MICHAEL F. RATCHFORD, ESQUIRE Address: EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTIFF Telephone: 570-558-5510 EX. 120 Supreme Court ID No. 86285 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 FU5— i i=iL: THE PROTHONOTARY 'e Ire1AP r PR 4 HHO,NO 2 R JUN —9 PM 3: O CUMBERLAND COUNTY PENNSYLVANIA 9 dt enitibe �• r,,,d OFF; F THE sHERiFF Equable Ascent Financial LLC vs. Tara L. Mosel Case Number 2011-6761 SHERIFF'S RETURN OF SERVICE 06/06/2014 11:40 AM - Christopher Sharpe, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank, 604 E High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to David Pletcher, Personal Banker, 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 him. %/2,2 ER SHARPE, DEPUTY SO ANSWERS, June 09, 2014 RONNY R ANDERSON, SHERIFF (C) CounlySuite Sheriff, Teleosoft, Inc. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ttL P{ DTHONOIR ()PRICE OF THE SHERIFF 2 I JUINN -9 Pii 3: 05 CUMBERLAND COUNTY PENNSYLVANIA Equable Ascent Financial LLC vs. Tara L. Mosel Case Number 2011-6761 SHERIFF'S RETURN OF SERVICE 06/06/2014 03:09 PM - Christopher Sharpe, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, New Cumberland Federal Credit Union, 6692 Carlisle Pike, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Briana Howsare, Branch 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 June 9, 2014 to Tara Mosel at 803 Rosemont Avenue, New Cumberland, PA 17070. %�2cv CHRIST r7PHER SHARPE, DEPUTY SO ANSWERS, June 09, 2014 RONNY R ANDERSON, SHERIFF ici CountySuite Sheriff, Teleosoit, inc. EQUABLE ASCENT FINANCIAL LLC In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division vs. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 vs. NO: 11-6761 CIVIL Defendant : Praecipe to Dissolve the Attachment against Garnishee NEW CUMBERLAND FCU 6692 CALISLE PIKE MECHANICSBURG, PA 17070 Garnishee . To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, ichael F. Ratchfo d, Esquire Edwin A. Abrah sen & Associates, P.C. Lawyer ID # 862: ge)?(Ligli EQUABLE ASCENT FINANCIAL LLC . In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division vs. TARA MOSEL 803 Rosemont Ave NEW CUMBERLAND PA 17070-0522 vs. WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG, PA 17050 : NO: 11-6761 CIVIL Defendant : Praecipe to Dissolve the Attachment against Garnishee Garnishee . To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, Michael F. Ratchfo . , Esquire Edwin A. Abrahar sen & Associates, P.C. Lawyer ID # 86 .•:5 PC/ 61/1‘0-. COW C Lit dc)q Rd %0°0 01 : ,