The URL can be used to link to this page

Home My WebLink About12-2556IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA ? -73 N _ CIVIL DIVISION '•'? `r rJ i:1 _K. ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 e-, Plaintiff Docket No. la•aSSll c ?r. r :r-- co f vs. NOTICE OF FILING RICHARD J. WRIGHT JUDGMENT 724 MIDDLE LANE CAMP HILL, PA 17011 Defendant PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: 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: MARCH 7, 2012 b. Amount: $.8,176.70 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: 724 MIDDLE LANE, CAMP HILL, PA 17011 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. r AORNEY FOR PL TIFF NAME: James T. Mulligan Esq. ATTORNEY ID NO: 51794 ADDRESS: P.O. Box 4031, Wyoming, PA 18644 TELEPHONE: (570) 207-1892, Ext. 235 DATE: L 0,'A SS. asp o " a -7429? Vw, ?? 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 RICHARD J. WRIGHT 724 MIDDLE LANE CAMP HILL, PA 17011 Defendant (X) Notice is hereby given that a JUDGMENT in the above-captioned matter has been entered against you in the amount of $ 8,176.70 on March 7, 2012 (X) A copy of all documents filed with the Prothonota ler ivil ion in sup of the within judgment is/are enclosed. Prot onotary/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) COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Di94. No: MDJ-09-1-03 MDJ Name: Honorable Richard S. Dougherty Address: 98 South Enola Drive, Suite 1 Enola, PA 17025 Telephone: 717-728-2805 Ability Recovery Services, LLC P.O. Box 4031 Wyoming, PA 18644 Disposition Summary Docket No MJ-09103-CV-0000011-2012 Judgment Summary Participant Ability Recovery Services, LLC Richard J Wright Plaintiff Defendant Ability Recovery Services, LLC Richard J Wright Ability Recovery Services, LLC V. Richard J Wright Docket No: M.1-09103-CV-0000011-2012 Case Filed: 2/1/2012 Disposition Disposition Date Default Judgment for Plaintiff 03/07/2012 Joint/Several Liability Individual Liability Amount $0.00 $0.00 $0.00 $0.00 $8,176.70 $8,176.70 Judgment Detail (*Post Judgment) In the matter of Ability Recovery Services, LLC vs. Richard J Wright on 3/07/2012 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 $8,023.70 $8,023.70 Filing Fees $0.00 $153.00 $153.00 Grand Total: $8,176.70 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 JUDGMENT/TRANSCRIPT 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. n MAR 2012 Date M isterial Dis ict dge Ricfiard S. Doug certiTy tnat tnis is a true ana correct copy p 6 2012 Date MDJS 315 Page 1 of 2 Printed: 03/12/2012 10:36: ,;2 s'??o? / 12c;?o1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND Number: 09-1-03 MDJ Name: Hon. RICHARD S. DOUGHERTY, JR. Address: 98 SOUTH ENOLA DRIVE, SUITE 1 ENOLA, PA 17025 Telephone: (717)728-2805 AMOUNT DATE PAID FILING COSTS $ /1/3,ob l l POSTAGE $ `a W SERVICE COSTS $ CONSTABLE ED. $ TOTAL $ 153.00 CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS F- ABILITY RECOVERY SERVICES,LLC PO BOX 4031 WYOMING, PA 18644 ? VS. ? DEFENDANT: NAME and ADDRESS F- RICHARD J. WRIGHT 724 MIDDLE LANE CAMP HILL, PA 17011 1 -1 I Docket No.: 4,ft,- Date Filed: FEB 012012 1 Social security numbers and financial information (e.g. PINS) should not be listed. If the identity of an account number must be established, list only the last four digits. 204 Pa. Code §§ 213.1 - 213.7. Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 8.023.70 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): RICHARD J WRIGHT is indebted to CHASE BANK USA credit card bearing account number XXXXXXXXXXX5395 in the amount of $8,023.70 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES, LLC on NOVEMBER 1, 2011 and last payment was made on JUNE 29, 2009. I, Christopher Munley Authorized Agent, verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. u G Agent) (Signs re of Plaintiff f, A7.MD.J.207.1. The plaintiffs attorney shall file an entry of appearance with the magisterial district court pursuant to Pa.R.C. IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO, JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT. If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the date set for the hearing. If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services, please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation. AOPC 308A-11 hl' H: 'PENNSYLVANIA. 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. RICHARD J. WRIGHT 724 MIDDLE LANE CAMP HILL, PA 17011 Defendant(s) . 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, RICHARD J WRIGHT, 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, 1-3 'Ll Da ed J MCS T. MULLIGAN, ESQ A? ID#: 51794 In House Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 207-1892 Ext 235 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WAYOMING, PA 18644 Plaintiff VS. RICHARD J. WRIGHT 724 MIDDLE LANE CAMP HILL, PA 17011 Defendant MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Garnishee TO THE PROTHONOTARY: ? o c fi =M a= ::go --•c r" _10rn J.D. No.:12-2556-N ?t ? G ? O yr cJ .?,, per E.D.,.C .. . i r-n PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution on the above matter, directed to the Sheriff of Cumberland County (1) You are directed to levy upon the property of the Defendant and sell his interest therein, against Richard J. Wright, Defendant; and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Richard J. Wright; (3) and enter this writ in judgment index (a) against Richard J. Wright, Defendant, and (b) against Members First Federal Credit Union, as garnishee, as a lis pendens against real property of the defendant in the name of garnishee as follows: n/a JUDGMENT: 8,176.70 INTEREST: $92.46 PROTHONOTARY: $ SHERIFF: $ TOTAL Iti ?`? Dated 31.?s 6? $p a vv K;CTULLY -r. SUB 1TED, . ome T. Mulligan,lr., Esq. ox 4031 Wyoming, PA 18644 PA ID # 51794 (866) 760-6205 ext. 235 In-House Counsel for Plaintiff In, 10 41 Sm ? a1 S4/S 0?v °? & 1yocd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-2556 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ABILITY RECOVERY SERVICES, LLC Plaintiff (s) From RICHARD J. WRIGHT, 724 MIDDLE LANE, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON AND SELL ALL OTHER REAL AND PERSONAL PROPERTY BELONGING TO THE DEFENDANT. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS FIRST FEDERAL CREDIT UNION, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055 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$8,176.70 L.L. $.50 Interest $92.46 Atty's Comm % Atty Paid $62.75 Plaintiff Paid Due Prothy $2.25 Other Costs Date: MAY 18, 2012 (Seal) REQUESTING PARTY: Name : JAMES T. MULLIGAN, JR., ESQUIRE Address: P.O. BOX 4031 WYOMING, PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 EX. 235 David D. Buell, Prothonotary Deputy Supreme Court ID No. 51794 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff vs. RICHARD J. WRIGHT 724 MI,IDDLE LANE CAMP HILL. PA 17011 Defendant and MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Garnishee .I.D. No. 12-2556-CV E.D. PLAINTIFF'S INTERROGATORIES TO G TO MEMBERS FIRST FEDERAL CREDIT UNION (Garnishee): You are required to file answers to the following interrogatories within thirty (30) days after service upon you. Failure to do so may result in judgment against you: At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? JC'S 2 At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? '?) At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest`? Y , RECEIY D MAY 2482 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? * 1 U At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent, and, if so, what was the consideration therefore? N O At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so. identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. l -0 8. If you are a bank or other financial institution, 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 exec option under 42 Pa.C.S. 8121. [f so, identify each account. Rp DATE: 05-14-12 RECEIVED MAY 2 4 2012 knVT,. Mulligan. Jr. , Esqu' 1 NVN omins. PA 18644 PA 11) # 51794 (866) 760-6205 ext. 235 \ttornc\ for Plaintiff VERIVICATION Understanding that false statements herein are made subject to the penalties of 18 PA.C.S. §4904, Unsworn Falsification to Authorities. I verify that I am of Garnishee in the above matter and that, after inquiry, the facts set forth in the foregoing Answers to Interrogatories are true, correct, and complete to th : best of my knowledge, information, and belief. DATE; Sionature pNCENEd MAY 2 4-2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith rk Gwl_ .., : , Chief Deputy - Richard W Stewart 2012 HA Y 3 Q A 8: 5 Solicitors Ability Recovery Services, LLC vs. Case Number Richard Wright 2012-2556 SHERIFF'S RETURN OF SERVICE 05/24/2012 09:44 AM - Elizabeth Muller, Deputy Sheriff, who being duly sworn according to law, states that on May 24, 2012 at: 0944 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Richard Wright, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Melinda Wilkins, 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 her. SO ANSWERS, May 29, 2012 RON R ANDERSON, SHERIFF Eliz beth Muller, Deputy IN THE COURT OF COMMON PLEAS CUMERLAND COUNTY, PENNSYLVANIA, 4 r , ? °., hJ L? i 1 R ABILITY RECOVERY SERVICES. LLC BOX 4031 WYOMING, PA 18644 Plaintiff NO.: 2012-2556 vs. RICHARD ,I. WRIGIIT 724 MIDDLE LANE. CAMP HILL, PA 17011 Defendant MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MF,CIIANICSBURG, PA 17055 Garnishee PRAECIPE FOR JUDGMENT BY ADMISSION AGAINST GARNISHEE, MEMBERS FIRST FEDERAL CREDIT UNION, ONLY TO THE PROTHONOTARY: Kindly enter Judgment By Admission for Plaintiff, Ability Recovery Services, LLC, against Members First Federal Credit Union, Garnishee, only, in the amount of $1,237.03, pursuant to said Garnishee's Answer to Plaintiff, Ability Recovery Services, LLC,s Interrogatories in Attachment hereto, and index same in the judgment index. Please send a copy of the judgment to all parties, pursuant to Pa. R.C.P. 236. Plaintiff reserves the right to refrain from discontinuing attachment and to proceed against the garnishee as to any further property or to contest any, right in the property claimed by the garnishee. act %1U.5c>Pd 'a mc,?IkA DATE: RESP CTFULLY SUBMITTED .1 n Brazil, Esquire c, P.O. Box 4031 Wyoming, PA 18644 PA ID # ,?5-v (866) 760-6205 ext. 235 In House Counsel for Plaintiff JUDGMENT Now this I y day of ?UtAel ?012, .judgment is entered for Plaintiff, Ability Recovery Services, LLC, against Members First Federal Credit Union, Garnishee, only, in the amount of $1,237.03, which is indexed in the judgment index. A copy of said judgment is sent to all parties, per Pa. R.C.P. 236. Prothonotar Bv: .? ?"- Deputy A rVis MEMBERS 1St FEDERAL CREDIT UNION May 30, 2012 James T Mulligan, Jr, Esq. Po Box 4031 Wyoming, PA 18644 RE: Writ of Execution for Richard J Wright Dear Mr Mulligan: A search of our records has revealed checking accounts and savings accounts bearing the name Ricahrd J Wright with an address of 724 Middle Ln, Camp Hill, PA 17011. The account balances reflect an available balance of $1537.03. Pursuant to the writ, all funds in the aforementioned accounts have been frozen. The accounts have been restricted from any withdrawal transactions. Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the total balance of both accounts exceeds the general monetary exemption under 42 Pa. C.S. § 8123 and therefore are attachable. Since the funds contained in these accounts are attachable, and the account has been restricted from any withdrawal transactions, any deposits will be held for attachment until the amount above is satisfied. Should you have any questions or need any additional information, feel free to contact me at (800) 283-2328, ext. 6022. Sincerely, Jkc Alice McCloskey Deposit Operations Analyst 03 a 3"7 D? 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.memberslst.org IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff VS. RICHARD J. WRIGHT 724 MIDDLE LANE CAMP HILL. PA 17011 Defendant and MEMBERS FIRST FEDERAL CREDIT UNION 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 Garnishee J.D. No. 12-2556-CV E.D. PLAINTIFF'S INTERROGATORIES TO GARNISHEE TO MEMBERS FIRST FEDERAL CREDIT UNION (Garnishee): PYj, f ,..7 Y?J You are required to file answers to the following interrogatories within thirty (30) 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 subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? ICS 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? ?K) 3. At the time you were served or at any subsequent time did you hold legal title to an), property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest`? t t RECEIM MAY 242012 At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? N At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent, and, if so, what was the consideration therefore? 0 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? N If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which fiends are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those fiends on a recurring basis. 'IV-0 If you are a bank or other financial institution, 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 exec option under 42 Pa.C.S. § 812 39 If so. identify each account. Rp DATE: 05-14-12 RECEIVED J• m s T. Mulligan, Jr., Esqu' P1.O. o\ 4031 W ominu. PA 18644 PA ID #51794 (866) 760-620 ext. 235 Attorney tier Plaintifl MAY 242012 VERIFICATION Understanding that false statements herein are made subject to the penalties of 18 PA.C.S. §4904. Unsworn Falsification to Authorities. I verify that I am of Garnishee in the above matter and that, after inquiry, the facts set forth in the foregoing Answers to Interrogatories are true, correct, and complete to th : best of my knowledge, information, and belief. DATE: Signature MAY 2 42012