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Home My WebLink About12-2960IN 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 DOUGLAS E ROSS 510 LAMP POST LANE CAMP HILL, PA 17011 VS. Docket No. ??- ?Ll L .yI NOTICE OF FILING JUDGMENT Defendant r., PRAECIPE FOR ENTRY OF JUDGMENT -ZM TO THE PROTHONOTARY: 1. Enter judgment on the attached: ( ) Instrument confessing judgment or authorizing confession by an attorney at auror other person against the person who executed it. ( X ) Certified copy of judgment from a District Justice. ( ) Other (please describe) ......................... .......... a. Date of Instrument: APRIL 9, 2012 b. Amount: $ 12,149.00 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: 510 LAMP POST LANE, CAMP HILL, PA 17011 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. LLB- ?! A RNEY FOR PLAINTIFF DATE: `l ?- r NAME: James T. Mulligan Esq. ATTORNEY ID NO: 51794 ADDRESS: P.O. Box 4031, Wyoming, PA 18644 TELEPHONE: (570) 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 VS. DOUGLAS E ROSS 510 LAMP POST LANE CAMP HILL, PA 17011 Defendant(s) Docket No. n , `7 -- ? c- a - nJ 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, DOUGLAS E ROSS, 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, Dated JA S T. MULLIGAl , Q A Y ID#: 51794 In House Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 207-1892 Ext 235 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLA,.'ID xN Mag. Dist. No: MDJ-09-3-04 MDJ Name: Honorable Paula P. Correal Address: 5275 East Trindle Road Suite 110 Mechanicsburg, PA 17050 Telephone: 717-697-2201 Ability Recovery Services, LLC P.O. Box 4031 Wyoming, PA 18644 Disposition Summary Docket No MJ-09304-CV-0000074-2012 Judgment Summary Particioant Ability Recovery Services. LLC Douglas E. Ross Plaintiff Defendant Ability Recovery Services, LLC Douglas E. Ross Joint/Several Liability $0.00 $0.00 Judgment Detail (*Post Judgment) In the matter of Ability Recovery Services, LLC vs. Douglas E judgment was awarded as follows: Judgment Component Joint/Several Liability Civil Judgment $0.00 Filing Fees $0.00 Costs $0.00 Individual Liability $0.00 $12,149.00 Amount $0.00 $12,149.00 Ross on 4/09/2012 the disposition is Default Judgment for Plaintiff and Individual Liability Deposit Applied Amount $12,000.00 $12,000.00 $143.00 $143.00 $6.00 $6.00 Grand Total: $12,149.00 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH , "*TUF,-+aDROTHONOTARY/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, -k t*.OR HERWISE COMPLIES WITH THE JUDGMENT. J D to is a true ano correct copy -- y-/2-- nior Magisterial Di ict Judge Paula Correal ainmg t e g t. sterial District Ju e, 1 " 3/ o 7 7 MDJS 315 Page 1 of 2 Notice of JudgmentlTranscript Civil Case Ability Recovery Services, LLC V. Douglas E. Ross fTlCa'' ? A r1_Ns Docket No: MJ-093(j-&- 0000074 (92 Case Filed: 315/2012 ,`- 7 ' w N) Disposition Disposition Date Default Judgment for Plaintiff 04/09/2012 Printed: 04/09/2012 1 Y2 15: 52 PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND 09-3-04 MDJ Name: Hon. PAULA CORREAL Addmsa: 5275 EAST TRINDLE ROAD SUITE 110 MECHANICSBURG, PA 17050 Telephone: (717)697-2201 CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS ABILITY RECOVERY SERVICES, LLC PO BOX 4031 WYOMING, PA 18644 ? VS. ? DEFENDANT: NAME and ADDRESS F- DOUGLAS E. ROSS 510 LAMP POST LANE CAMP HILL, PA 17011 L_ I Docket No.: Date Filed: AMOUNT DATE PAID FILING COSTS $ //43.19a POSTAGE $ 00 / / Social security numbers and financial information SERVICE COSTS $ l l (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ l l account number must be established, list only the TOTAL $ 149.00 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 $ 12.000.00 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): DOUGLAS E. ROSS is indebted to CHASE BANK USA credit card bearing account number XXXXXXXXXXX4771 in the amount of $12,000.00 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES,LLC on JANUARY 7, 2012 and the last payment was made on SEPTEMBER 25, 2009. I, Christopher Munlev. 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. „ ` The plaintiff's attorney shall file an entry of appearance with the magisterial district court pursuant topX.R.C.P.M.D.J. 207.1. 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 30BA-11 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./-Q AP (, ? )VS. NOTICE OF FILING JUDGMENT DOUGLAS E. ROSS 510 LAMP POST 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 $12,149.00 on RIL 9 2012 (X) A copy of all documents filed with the Prothonota Cler , ivi ision in su of the within judgment isiare enclosed. / Prothonotary/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) WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-2960 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 DOUGLAS E. ROSS, 510 LAMP POST 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: 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 $12,149.00 L.L. $.50 Interest $139.30 Atty's Comm % Atty Paid $62.25 Plaintiff Paid Due Prothy $2.25 Other Costs Date: 6/20/12 (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 Supreme Court ID No. 51794 Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLW IA _? 4- ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 t ,;fi`?'? ? it rn` Plaintiff J.O. No.: 12-2960-CV VS. DOUGLAS E. ROSS 510 LAMP POST LANE CAMP HILL, PA 17011 E.D. Defendant TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION (LEVY - PERSONAL PROPERTY) 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 Douglas E. Ross, Defendant; and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Douglas E. Ross; (a) and enter this writ in judgment index against Douglas E. Ross, Defendant JUDGMENT: $12,149.00 INTEREST: $139.30 PROTHONOTARY: $ SHERIFF: $ TO ALA Dat d CIS) a4l ? 31.as Cyr ? a, as PA ag) RESPECTFULLY SUBMITED, "." "r (Jam. s T. Mulligan, Jr., Esq. Is 4031 Wyoming, PA 18644 PA ID # 51794 (866) 760-6205 ext. 235 In-House Counsel for Plaintiff .a.6 ?? 6. sa LL- 05 k- 0s Vz a? -?bog wra of ?xTssjej IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY; COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION-LAW 2 2: C Plaintiff ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 4 iS!`E-VA NIA No.: 12-2960-CV Defendant DOUGLAS E. ROSS 510 LAMP POST LANE CAMP HILL, PA 17011 WAIVER OF WATCHMAN Any Deputy Sheriff levying upon or attaching any property under this Writ may leave same without a watchman, in custody of whomever is found in possession, after notifying such person of such levy and attachment, without liability on the part of such Deputy or Sheriff to any Plaintiff herein for any loss, destruction or removal of any such property before Sheriff's Sale thereof. / Date: r.esT. T' Ja ulliga n, Jr., Esq. P 31 yoming. PA 18644 No.: 51794 In-House Counsel for Plaintiff Personal Property FACE SHEET Fite# Case Number Document Type Bankruptcy Case Number 2013-CV-01561-NT WRIT OF EXECUTION& INTERROGATORIES Received From: Date Received: 2/22/2013 Date Expires: C-) C= PEOPLE ASSOCIATED WITH THE CASE 0:3� t— rn. c_— Primary Defendant(s) 70 Name: DOUGLAS E ROSS DOB: CD Primary Plaintiff(s) 3;'n 2: Name: ABILITY RECOVERY SERVICES LLC DOB: C= Attorney: JAMES MULLIGAN,JR Firm: ABILITY RECOVERY SERVICES,LLC Attorney Phone: 866-760-6205 EXT 235 Attorney Address: PO BOX 4031 WYOMING,PA 18644 Garnshee(s) Name: PSECU-GARNISHEE DOB: Type of Service: PERSON IN CHARGE Address: I CREDIT UNION PLACE HARRISBURG,PA 17110 PERSONAL PROPERTY INFORMATION Monies Levied: Date of Sale: Date of Levy: District Justice: COMMENTS 2/25/2013 SENT GARNISHMENT OUT WITH DEPUTIES 2/26/2013 DEPUTY CONWAY COMPLETED THE GARNISHMENT SENT RETURNS AND WRIT TO STAY TO ATTY WRIT IN FEBRUARY LETTER FILE 3/12/2013 RECEIVED FORMAL REQUEST BACK FROM ATTY NO PAYMENT 6/11/2013 RETURNED WRIT TO CUMBERLAND COUNTY PROTHY- EXPIRED SENT COPY OF FACE SHEET TO DAUPHIN PROTHY Cash Accounting Amount Date Added Category ID $200.00 2/25/2013 Deposit Agency 445535 ($87.00) 6/11/2013 Sheriff Costs 453480 ($1.74) 6/11/2013 Poundage 453481 ($20.00) .6/11/2013 State Fee .453482 ($91.26) 16/11/2013 lRefund to Atty/Plff 1453483 1 Total Number of Rows: 5 Balance Due: $0.00 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2012-2960 Civil COUNTY OF CUMBERLAND) CIVIL ACTION–LAW t�� - TO THE SHERIFF OF DAUPHIN COUNTY: C,��`� �, Y RECOVERY SERVICES L C Plaintiff s To satisfy the debt,interest and costs due ABILIT ( ) From DOUGLAS E.ROSS,510 LAMPPOST LANE,CAMP HILL,PA 17011 (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: PA STATE EMPLOYEES CREDIT UNION, 1 CREDIT UNION PLACE,HARRISBURG,PA 17106 and to notify the gamishee(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 $12,149.00 L.L. C= rn C),n Interest $604.00 r�*z= S`n ' tv °-r_T' Atty's Comm % Due Prothy$2.25 C-) v Atty Paid $211.91 Other Costs V- Plaintiff Paid ._ Date: 02/11/2013 —lad AL/[�_� David D.Buell,Prothonotary (Seal) ' Deputy REQUESTING PARTY: Name : JAMES T. MULLIGAN,JR.,ESQUIRE Address: P.O.BOX 4031 WYOMING,PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 EXT 235 TRUE COPY FROM RECORD In Testimony whereof, I here unto set my hand Supreme Court ID No. 51794 and the seal of said Court at Carlisle, Pa. him day of 20 'i' Pro h notary r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 �_ ' °' WYOMING, PA 18644 �ai d Rte0 • NO.: 42__.960n-. t t7rt • 3'C DEFENDANT • %c • DOUGLAS E. ROSS • 510 LAMP POST LANE • CAMP HILL, PA 17011 NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1,notice is hereby given that on January 9, 2014, at 11:00 AM, at the law offices of James T. Mulligan, Esq., 321 Spruce Street, Suite 300, Scranton, Pa 18503, 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 king (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). ,r • 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: I) L1 $ Respectfully Submitted, edt-^^4'' 1: )\A J. - T. Mulligan, Jr., Esq. l P. . -• 51794 In-'ouse Counsel for Plaintiff 570-207-1892 (ext. 235)