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
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PRAECIPE FOR ENTRY OF JUDGMEN a
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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
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Esquire Attom# for Plaintiff
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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.?
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-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
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.50 LL writ e?
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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?
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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 $
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chae r i Ratchford, Esquir
Edwin A. Abrahamsen & As ociates, P.C.
Attorney for Plaintiff
mratchford@eaa-law.com
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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 : ,