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Home My WebLink About11-8846In SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF. F . >._G -. qq Ft! ED- -F'CF C- R1P t 't07iiC, iA R Y 0 f?J""'N-6 A11 8: C?M3EPL A N 0 CO«?iI i Y PENNSYL!'AAiA Ability Recovery Services, LLC Case Number vs. Briana K. Turner 2011-8846 SHERIFF'S RETURN OF SERVICE 01/03/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Briana K. Turner, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Briana K. Turner. Request for service at 33 William Penn Drive, Apartment 1, Camp Hill, Pennsylvania 17011 the Defendant was not found. To date The Camp Hill Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST: $48.00 SO ANSWERS, January 03, 2012 RON R ANDERSON, SHERIFF ?urty 1 1 SJ11.lnc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL iVISION PLAINTIFF ABILITY RECOVERY SERVICES LLC P.O. BOX 4031 WYOMING. PA 18644 vs. NO.: 11-8846-Civil ROT r1?IN0T 2-3I2 APB? °4 AM E0: 48 cUMBERLAND COUNT`` pEhI?jSYLVANA COMPLAINT IN CIVIL ACT DEFENDANT BRIANA TURNER 14 GEORGE CIRCLE MECHANICSBURG, PA 17055 PRAECIPE TO RE''_NSTATE COMPLAINT TO THE PROTHONOTARY: PLEASE REINSTATE COMPLAINT IN CONNECTION WITH THE ABOVE CAPTIONED MATTER. PLEASE FORWARD FILED COPY TO SHERIFF. DATE: 13 12 RESPECTFULLY SUBMITTED James T. Mulligan, Jr., Esq. (/" P.O. Box 4031 Wyoming, PA 18644 PA ID # 51794 (866) 760-6205 ext. 235 In House Counsel for Plaintiff Dauu? ®ll. ? s pd aH? ?(L4.L yu3(S ?-* o-i3 Sa3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , Sheriff ' Jody S Smith Chief Deputy -, Richard W Stewart -' µ Solicitor Ability Recovery Services, LLC I vs. Case Number Briana K. Turner 2011-8846 SHERIFF'S RETURN OF SERVICE 04/09/2012 07:56 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2012 at 1956 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Briana K. Turner, by making known unto herself personally, at 14 George Circle, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. AW TSHAL , SHERIFF COST: $38.00 April 12, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANJA CIVIL DIVISION i r PLAINTIFF L ?? 1 ?Ultlf?'7 Y ri' i`k i? ABII,ffY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING. PA 18644 NO.: 11-8846-CV vs. DEFENDANT BRIANA TC?RNER 14 GEORGE CIRCLE MEClIANICSBURG. PA 17055 PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter and index the judgment for Ability Recovery Services, LLC against Briana burner, in the amount of $17.216.42, plus statutory interest and costs. Default Notice pursuant to PA. R.C.P. 237.1(A)(2) and proof of mailing of same is attached, and more than ten (10) days has elapsed since service of same. Notice of Judgment to he given to all parties pursuant to PA. R.C.P. 236. Dated: Y\A? Signature: J mes T. Mulligan, Jr.. Esq. Address: .O. Box 4031 Wyoming, PA 18644 Attornev for: Plaintiff Telephone: 570-207-3383 ext. 235 Supreme Coutt ID: 51794 askk & `to Sol OA a j f??? A? a• .JUDGMENT RN 0-b * rVla+led Now, this day of t , 2012, judgment for Ability Recovery Services, LI.-C, against Briana turner. in the amount f $17,216.42, plus statutory interest plus costs is hereby entered and indexed in the judgment index. Notice of judgment to all parties is hereby given pursuant to Pa. R.C.P. 236. 11 Protho/l6tarvO*x 7D v: vt9L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABIi,I I,Y RE:000RY SERVICES, 1,1,C' P.O. BOX 403 I WYOMING. PA 18644 vs. DEFENDANT NO.: 11-8846-('V COMPLAINT IN CIVIL ACTION BRIANA TIIRNI:R 14 GH )RG1-: CIRCH", 2526 Mf:('ELiN'R'SBl ERG. PA 17055 31? 278 Cp03 6814 - - I o: BRIANA. TURNER, DEFENDANT - Dme ol'Nolicc: April -30.2012 IMPORTANT NOTICE, PURSUANT TO PA.R.C.P. NO. 237.1(A)(2) YOU ARF IN Df-iFAUI_ I'13EC'AUSI'. YOII HAVE 1=A11.1:1) l'O I NTER A WRITTEN APPEARANCE, PERSONAI.I.`r' OR BY A"I'TORNf Y AND FII_T' IN WRI HN(i WI I'I I TTTF: ('01 1RT YOUR DI?FENSES OR OBJECTIONS hO H II' CLAIMS SE'T FORTH AGAINST` YOU. I INUF:SS YOU ACT WITHIN (10) TEN DAYS FROM I lil: DA II: OF THIS NOTICE, A JUDGMLNI'MAY BE E'.NTERI'.D AGAINST YOU WITHOUT A I IFARING AND YOU MAY LOSE YOUR PROPER'I Y OR OTHER IMPORTANT RIGHTS. YOl I' l-IOtII.D "I'AKI, TATS PAPER "LO YOUR I,AWYL:R A'I- ON(-'I,. IF YOU DO NOT IJAVE A 1,AWYER, GU lY) OR 'TEI.F,PHONE "1'HE OI FICE SI:T FOR'I I I BELOW. THIS OFFICE CAN PROVIDE YOU WITH INE'010vtATION ABOUT AIRING A EAWYFR. IF YOU CANNOT AFFORD TO IIIRI: A LAWYER, HIIS OFFICE MAY BE ABLE I'O PROVIDE YOU WI III INFORMA"PION ABOUT AGENCiF:S `HIAT MAY 01-TER 1.11 'AL SF?RVICES TO ELJGIBEF. PERSONS A ['A REDUCED I'll", OR NO 1.11,1,. LAWYER REFERRAL, SERVICE 4"" FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 240-62011 Signahue:? .James T. Mulligan,,Ir. Address: I. P.O. Box 4031 Wyoming, PA 18644 Attorney tier: Plaintiff Fclcphone: 866-760-6205 ext. 235 Supreme Col_u-t ID: 51794 ru Ln ru S' ri CO Postage S ..0 Certiticd Fee M D Return Receipt Fee C3 (Endorsement Required) C3 Restricted Delivery Fee O (Endorsement Required) 1-0 ['? Total Post ay Fees f1J Sent To O 13 Streel, Apt Nn.; -- PO B 13 or ox Yo. City, J3taVLP+4 , t t7? t.l1, 45 fl'18? ?.95 ,for PA ?-;. P k $!1,1.11! /? C $?1,17f1 ; ,n LID 2011 "X -------------------------- THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES. LLC P.O. BOX 4031 WYOMING. PA 18644 Plaintiff(s) File No.: 11-8846-CV VS. BRIANA TURNER 14 GEORGE CIRCLE MECHANICSBURG, PA 17055 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE I, James T. Mulligan, Jr., Esq.. In-House Counsel for Plaintiff, state that to the best of my knowledge, information and belief. that the Defendant., Briana Turner, is not in the military service as defined in the Soldiers' & Sailors" Relief Act of 1940 and its amendments thereto. Plaintiff further says that the obligation sought to be enforced in this suit is not an obligation against a surety, guarantor, endorser, or other person liable, primarily or secondarily for a party in the military service. Dated:- - r?(L RESPECTFULLY SUBMITTED, 4f7 T. MULLIGAN, .1R., ESQ. / ATTY I D#: 51794 //In House Counsel for Plaintiff Box 40311, Wyoming, PA 18644 (570) 207-1892 Ext 235 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES. LLC 1). 0. I3(-)?C 4031 WYOMING, PA 18644 vs. DEFENDANT BRIANA TURNER 14 GEORGE CIRCLE MECHANICSBURG, PA 17055 NO.: 11-8846.C V Pa. R.C.P. 236 NOTICE Notice of.ludgment to be given to all parties pursuant to PA R.C.P. 236. Respectfully Submitted. 1 Date: J "'es T. Mulligan, Jr., Esq. I) Y ox 4031 Wyoming, PA 18644 PA ID 4 51794 In House Counsel for Plaintiff SI Ito PLAINTIFF IN THE COURT OF COMMON PLEAS ` °' _ + r 0 CUMBERLAND COUNTY PENNSYLVA X4 JIo?.. _ 9 r.,!;1 CIVIL DIVISION tie Cl.! �Etif�SYL VA VANIA ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT BRIANA TURNER 14 GEORGE CIRCLE MECHANICSBURG, PA 17055 NO.: 11 -8846 -CV NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on July 24, 2014, at 11:00 AM, at the law offices of James T. Mulligan, Esq., 1 Montage Mountain Road, Suite A, Moosic, Pa 18507, your oral deposition will be taken for the purposes of discovery in aid of execution. You are directed to attend the deposition. You are also directed to bring with you all documents in your possession, or to which you have access, relating to the following: 1. Deeds for each property in which you have an interest if any kind (individually or jointly with someone else). 2. All mortgages on all real estate in which you have an interest of any kind (individually or jointly with someone else). 3. All amortization statements (schedule of mortgage payments) for each mortgage. 4. Bank statements from the last six months for all checking accounts, savings accounts, certificate of deposits and statements or mailings from any brokerage firm, in which you have an interest of any kind (individually or jointly with someone else). 5. All titles to vehicles in which you have an interest of any kind (individually or jointly with someone else). 6. All documents of title for any assets you or your spouse own, including any mobile home. 7. Your federal income tax returns for the last three (3) years. 8. All documents that show that money is owed to you by someone else. 9. All lists and documents showing inventory or stock in trade in any business that you may operate, have operated, or intend to operate, whether individually or jointly with someone else. 10. All documents showing or referring to any interest you have in any partnerships, giving the name and address of your partners, the business of the partnership, and its business address. 11. All receipts and documents showing all deposits of money with any escrow agent, credit union, public utility company, landlord, or others. 12. All lists and documents showing machinery, fixtures, equipment, tools, and supplies used in any business in which you have an interest of any kind (individually or jointly with someone else). 13. All documents related to patents, copyrights, franchises, and other general intangibles in which you have an interest of any kind (individually or jointly with someone else). 14. All lists and documents relating to government and corporate bonds and other negotiable and non-negotiable instruments in which you have an interest of any kind (individually or jointly with someone else). 15. All documents showing any debts owed to you or to any business in which you have any interest. 16. All bills of exchange or promissory notes or obligations owed to you by others. 17. All annuities and insurance policies in which y-ou have an interest of any kind (individually or jointly with someone else). 18. All certificates or records of ownership of al bonds and stocks or any interest in incorporated or unincorporated companies in which you may have an interest. Dated: Respectfully Submitted, s T. Mulligan, Jr., sq. Paid #51794 In -House Counsel for Plaintiff 570-207-1892 (ext. 235) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT BRIANA TURNER 5160 E. TRINDLE ROAD, APT. 1 MECHANICSBURG, PA 17050 NO.: 11 -8846 -CV NOTICE OF DEPOSITION IN Ali) OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on January 22, 2015, at 11:00 AM, at the law offices of James T. Mulligan, Jr.. 1 Montage Mountain Road, Suite A, Moosic, PA 18507, your oral deposition will be taken for the purposes of discovery in aid of execution. You are directed to attend the deposition. You are also directed to bring with you all documents in your possession, or to which you have access, relating to the following: 1. Deeds for each property in which you have an interest if any kind (individually or jointly with someone else). 2. All mortgages on all real estate in which you have an interest of any kind (individually or jointly with someone else). 3. All amortization statements (schedule of mortgage payments) for each mortgage. 4. Bank statements from the last six months for all checking accounts, savings accounts, certificate of deposits and statements or mailings from any brokerage firm, in which you have an interest of any kind (individually or jointly with someone else). 5. All titles to vehicles in which you have an interest of any kind (individually or jointly with someone else). 6. All documents of title for any assets you or your spouse own, including any mobile home. 7. Your federal income tax returns for the last three (3) years. 8. All documents that show that money is owed to you by someone else. 9. All lists and documents showing inventory or stock in trade in any business that you may operate, have operated, or intend to operate, whether individually or jointly with someone else. 10. All documents showing or referring to any interest you have in any partnerships, giving the name and address of your partners, the business of the partnership, and its business address. 11. All receipts and documents showing all deposits of money with any escrow agent, credit union, public utility company, landlord, or others. 12. All lists and documents showing machinery, fixtures, equipment, tools, and supplies used in any business in which you have an interest of any kind (individually or jointly with someone else). 13. All documents related to patents, copyrights, franchises, and other general intangibles in which you have an interest of any kind (individually or jointly with someone else). 14. All lists and documents relating to government and corporate bonds and other negotiable and non-negotiable instruments in which you have an interest of any kind (individually or jointly with someone else). 15. All documents showing any debts owed to you or to any business in which you have any interest. 16. All bills of exchange or promissory notes or obligations owed to you by others. 17. All annuities and insurance policies in which you have an interest of any kind (individually or jointly with someone else). 18. All certificates or records of ownership of al bonds and stocks or any interest in incorporated or unincorporated companies in which you may have an interest. Dated: Respectfully Submitted, es T. Mulligan, Jr., lq. d # 51794 In -House Counsel for Plaintiff 570-207-1892 (ext. 235)