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Home My WebLink About12-1934IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff VS. NOTICE OF FILING TRACEY L. KEEFER JUDGMENT 316 LIBERTY DR SHIPPENSBURG, PA 17257 - a Defendant r` rv PRAECIPE FOR ENTRY OF JUDGMENT -_77, TO THE PROTHONOTARY: Y` Docket No. /a - 1Q34 0 ivi I Term ,.t =M, 1. Enter judgment on the attached: ( ) Instrument confessing judgment or authorizing confession by an attorney at law or other person against the person who executed it. ( X ) Certified copy of judgment from a District Justice. ( ) Other (please describe) _ ---------------------------------- a. Date of Instrument: October 13, 2011 b. Amount: $ 9,065.12 2. Enter the judgment in favor of the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3. I hereby certify that the residence of the plaintiff is: P. O. BOX 4031, WYOMING, PA 18644 I hereby certify that the residence of the Defendant is: 316 LIBERTY DRIVE, SHIPPENSBURG, PA 17257 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. Au,, -r- *4/ T ORNEY FOR PLAINTIFF NAME: James T. Mulligan Esq. ATTORNEY ID NO: 51794 ADDRESS: P.O. Box 4031, Wyoming, PA 18644 TELEPHONE: (570) 207-1892, Ext. 235 DATE: -2J-L / -I- 431•&5 PA AnN C* ?F34c?1 ? a7a98?- Wice Mailed COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ-09-3-01 MDJ Name: Honorable H. Anthony Adams Address: 35 West Orange Street Shippensburg, PA 17257 Telephone: 717-532-7676 Ability Recovery Services, LLC P.O. Box 4031 Wyoming, PA 18644 Ability Recovery Services, LLC V. Tracey L Keefer Docket No: MJ-09301-CV-0000221-2011 Case Filed: 9/16/2011 Disposition Summary MA.R 0 20 . Docket No Plaintiff Defendant Disposition Disposition Date MJ-09301-CV-0000221-2011 Ability Recovery Services, LLC Tracey L Keefer Default Judgment for Plaintiff 10/13/201' Judgment Summary Participant Joint/Several Liabilitv Individual Liability Amount Ability Recovery Services, LLC $0.00 $0.00 $0.00 Tracey L Keefer $0.00 $9,065.12 $9,065.12 Judgment Detail (•PostJudgment) In the matter of Ability Recovery Services, LLC vs. Tracey L Keefer on 10/13/2011 the disposition is Default Judgment for Plaintiff and judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $8,914.12 $8,914.12 Costs $0.00 $151.00 $151.00 Grand Total: $9,065.12 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 JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL, SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. y}}N ep f o/(f J/^ ?j.?./Jf/J//ff/fy/ /{/ // nt }Kpy Uq„y Date Magisterial District Judge Brenda M. Knepper certify that this is a true an correct copy o the record o the proceedings cont ning the judgment. Date Magisterial District Judge j? MDJS 315 Page 1 of 2 Printed: 03/06/2012 2:25:05PM ? ? ? IN THE COURT OF COMMON PLEAS OF' CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Vs. TRACEY L. KEEFER 316 LIBERTY DR SHIPPENSBURG, PA 17257 Defendant(s) Docket No. AFFIDAVIT OF NON-MILITARY SERVICE I, James T. Mulligan., Attorney for Plaintiff, state that to the best of my knowledge, information and belief, that the Defendant, TRACEY L KEEFER, 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. RESPECTFULLY SUBMITTED, 3?Z12 ? J Dat d J ME T. MULLIGAN, SQ TT ID#: 51794 In ouse Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 207-1892 Ext 235 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Docket No. VS. NOTICE OF FILING JUDGMENT TRACEY L. KEEFER 316 LIBERTY DR SHIPPENSBURG, PA 17257 Defendant (X) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $ 9,065.12 on OCTOBER 13, 2011 (X) A copy ojudgment all documents filed with the ProthdlXary/G?rk, ?Divisio i port of the within is/are enclosed. -T'1"oThonotary/Clerk, Civil Division By: Deputy If you have any questions regarding this Notice, please contact the filing party: Name: James T. Mulligan, Esq. ATTY ID#: 51794 In House Attorney for Party: ABILITY RECOVERY SERVICES, LLC Address: PO Box 4031, WYOMING, PA 18644 Telephone: (855) 207-1892 Ext 235 (This notice is given accordance with Pa.R.C.P. No. 236) ` SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1c..1 ter ,L Ronn y RAnderson Sheriff is' It P R Jody S Smith Chief Deputy 21)13 JUN 10 All 10-- 1 Richard W Stewart CJMPaEKANu t~OWN11 ,r, Solicitor C .E OF TFE S IRWr P E N S Y LVA H I A Ability Recovery Services, LLC vs. Case Number Tracey L Keefer 2012-1934 SHERIFF'S RETURN OF SERVICE 11/27/2012 07:46 PM-Jason Kinsler, Deputy, being duly sworn according to law, states that on November 27, 2012 at 7:46 PM hours, served the requested Writ of Execution and Claim for Exemption Form by"personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Tracey L Keefer at 316 Liberty Drive, Southhampton Township, Shippensburg, PA 17257, informed Defendant of contents of same and levied upon personal property as directed. Postcard and copy of levy mailed to attorney and letter mailed to defendant on 11-28-12. 12/17/2012 On December 17, 2012 at 1530 hours, a property claim was filed byArthur W. Neil.All parties notified by mail 12-18-12. 12/27/2012 Reference is made to Property Claim dated December 18, 2012, entered by Arthur W. Neil, Writ of Execution No. 2012-1937, Ability Recovery Services, Inc., vs. Tracey L. Keefer. Ronny R. Anderson, Sheriff, has determined that the claimant,Arthur W. Neil, in the above mentioned property claim, is the owner of the property set forth in the claim. 01/08/2013 No objections filed with our office and/or with the prothonotary's office. Property remains; writ to remain open. 06/07/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $117.12 SO ANSWERS, (jZ, x June 07, 2013 RON R ANDERSON, SHERIFF law (c)CounlySuite Sheriff,Teleosoti,Inc. PLAINTIFF 4/' '0_ , IN THE COURT OF COMMON PLEAS l/1.1✓i�✓/ � CUMBERLAND COUNTY PENNSYLVANtAp /�4f0 �e'CIVIL DIVISION (,?4 A/+ , , 4, U. <=)4 3 ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT TRACEY L. KEEFER 316 LIBERTY DRIVE SHIPPENSBURG, PA 17257 NO. )2 -1934 -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 September 25,2014, 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 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: 7//0 't Respectfully Submitted, s T. Mulligan, Jr., Es d#51794 In -House Counsel for Plaintiff 570-207-1892 (ext. 235)