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Home My WebLink About12-4779 I 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 LOUIS LARSON 218 ROXBURY ROAD SHIPPENSBURG, PA 17257 Defendant . PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: -Q3 +v -mot ? = r- -_ ?? w o ? zp 3 71 - y-z w C -1 r^ 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: JUNE 12, 2012 b. Amount: $ 9,144.72 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. 1 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: 218 ROXBURY ROAD, SHIPPENSBURG, PA 17257 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. ?A Z TORNEY FOR PLAINTIFF DATE: 7/, NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 51794 ADDRESS: P.O. Box 4031, Wyoming, PA 18644 4 a,?Vq 7 PUS1 ,? x,1001 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. LOUIS LARSON 218 ROXBURY ROAD SHIPPENSBURG, PA 17257 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE I, James T. Mulligan, Esq., Attorney for Plaintiff, state that to the best of my knowledge, information and belief, that the Defendant, LOUIS LARSON, are 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. Wed RESPECTFULLY SUBMITTED, J s T. Mulligan, Esq. Y ID#: 51794 In House Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 207-1892 Ext 235 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Notice of Judgment/Transcript Civil 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 Disposition Summary Docket No MJ-09301-CV-0000109-2012 Judgment Summary Participant Ability Recovery Services LLC Louis Larson Plaintiff Defendant Ability Recovery Services LLC Louis Larson Joint/Several Liability Individual Liability $0.00 $0.00 $0.00 $9,144.72 Ability Recovery Services LLC', V. Louis Larson JUL 2 3 2012 Docket No: MJ-09301-CV-000010 -2012 Case Filed: 5/2/2012 Disposition Judgment for Plaintiff $9,144. 06/12/2012 Judgment Detail (*PostJudgment) In the matter of Ability Recovery Services LLC vs. Louis Larson on 6/12/2012 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amot Civil Judgment $0.00 $8,991.22 $8,991 Filing Fees $0.00 $153.50 $153 Grand Total: $9,14 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF THE PROTHONOTARY/CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF TH JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF T HOLDER ELECTS TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST CO 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 JUDGMEI REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN F OR OTHERWISE COMPLIES WITH THE JUDGMENT. Date Magisterial District Judge H. Anthony Adams a true an correct copy o the record o the proceedings containing the judgment. Date Magisterial District u ge MDJS 315 Page 1 of 2 'PEAL WITH NOTICE OF JUDGMENT FROM THE MAY FILE A L, SETTLES, AMA - P Printed: 06/12/201 Z/10:29:32AM 2112 JUL 30 PM 3= 14 CIJ RILAND COUNTY P SYLVANIA COMMONWEALTH OF PENNSYLVANIA COUNTY OF: Cll,MBEI RAND Number: 09-3-01 MDJ Name: Hon. HAROLD ANTHONY ADAMS Address: 35 WEST ORANGE STREET SHIPPENSBURG, PA 17257 I Telephone: (717)632-7676 CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS ABILITY RECOVERY SERVICES, LLC PO BOX 4031 WYOMING, PA 18644 phone: (855) 207-1892 VS. DEFENDANT: NAME and ADDRESS LOUIS LARSON 218 ROXBURY RD L_ SHIPPENSBURG, PA 17257 -? ? 11 Docket No.: Date Filed: 4?- FILING COSTS AMOUNT $ DATE PAID /10- POSTAGE SERVICE COSTS CONSTABLE ED. TOTAL $ $ $ $ 153.50 l l l I l / Social security numbers and financial informatio (e.g. PINS) should not be listed. If the identity of account number must be established, list only th 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): LOUIS LARSON is indebted to CHASE BANK USA credit card bearing account number XXXXXXXXXX0195 i the amount of $12,000.00 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES,LL on JANUARY 7, 2012 and the last payment was made on OCTOBER 20, 2009. I, JAMES T MULLIGAN. JR.. ESQ 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 o 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 distric co pursuant to Pa.R.C.P.M.D.J? 207.1. IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIAT LY AT THE ABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLE S 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 yo intend to assert at the hearing, you must file it on a complaint form at this office at least five (5) days before the ate 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 tel phone number. We are unable to provide transportation. AOPC 308A-11 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 12-4779 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 LOUIS LARSON, 218 Roxbury Road, Shippensburg, PA 17257 (I )You are directed to levy upon the property of the defendant (s)and to 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 $9,144.72 L.L. $.50 Interest -- $118.50 Atty's Comm % Arty Paid $62.25 Plaintiff Paid Due Prothy $2.25 Other Costs Date: 8/30/12 (Seal) REQUESTING PARTY: Name : JAMES T. MULLIGAN, JR., ESQUIRE Address: PO BOX 4031 WYOMING, PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 Ext. 235 David D. Buell, Prothonotary Deputy Supreme Court ID No. 51794 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff J.D. No.: 12-4779-CV VS. C') C na an TTM - T11 LOUIS LARSON E.D. ;z -y 218 ROXBURY ROAD F F SHIPPENSBURG, PA 17257 W - i G "q D f d t ""'21` "( e en an f G PRAECIPE FOR WRIT OF EXECUTION (LEVY - PERSONAL PROPERTY) TO THE PROTHONOTARY: 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 Louis Larson, Defendant; and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Louis Larson; (a) and enter this writ in judgment index against Louis Larson, Defendant JUDGMENT: $9,144.72 INTEREST: $118.50 PROTHONOTARY: $ SHERIFF: $ TOTAL. S CTFULLY SUBMITED, Dated Mulligan, Jr., Esq. r PB,x 4031 Wyoming, PA 18644 PAID#51794 (866) 760-6205 ext. 235 In-House Counsel for Plaintiff ?a8.,? Pa Amt 3i. a5 c,$F 6A.a5 . PQ A,ry -m'as &Co - So w e*46US3 o* dBD05o 4' & 4swed IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION-LAW Plaintiff ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 No.: 12-4779-CV Defendant LOUIS LARSON 218 ROXBURY ROAD SHIPPENSBURG, PA 17257 WAIVER OF WATCHMAN t ys. ?? Z xc's ?,? tv ?rTx --? N) 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: 411 1 v Jame T. Mulligan, Jr., Esq. P.O. ox 4031 yoming, PA 18644 No.: 51794 In-House Counsel for Plaintiff ABILITY RECOVERY IN THE COURT OF COMMON PLEAS OF SERVICES, LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION -LAW vs. NO. 12-4779 CIVIL LOUIS CARSON, Defendant IN RE: OBJECTIONS TO SHERIFF'S DETERMINATION ORDER AND NOW, this ~ ~ ~ day of November, 2012, hearing on the Plaintiff's Objections to Sheriff s Determination is set for Thursday, November 29, 2012, at 3:00 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. BY THE COURT, ~ - ~~ / Kevin .Hess, P. J. / James T. Mulligan, Jr., Esquire P. O. Box 264 Taylor, PA 18517 For the Plaintiff / Louis Larson 218 Roxbury Road Shippensburg, PA 17257 / Sheriff c~ c ~ ~--~ - , _,.,, tTt w ~ ~ ___ ~~ ...~ ~ ~- ~ cry ~1 D =_ . ~ ~_' --t ~ ~ -~. , :rlm ~~~ ~ ~, ~~~ ~~l/S~f /~ ABILITY RECOVERY IN THE COURT OF COMMON PLEAS OF SERVICES, LLC, CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff CIVIL ACTION - LAW V NO. 12-4779 CIVIL LOUIS CARSON, Defendant IN RE: OBJECTIONS TO SHERIFF'S DETERMINATION ORDER OF COURT AND NOW, this 29th day of November, 2012, after hearing, the objection of the plaintiffs, Ability Recovery Services, LLC, to the determination that the Sheriff made September 24, 2012, is dismissed. By the Court, ~/ n Hess, P.J. ~ Jason D. Arnold, Esquire P.O. Box 264 Taylor, PA 18517 For the Plaintiff ~ouis Larson 218 Roxbury Road Shippensburg, PA 17257 Sheriff ~ ~~_~;v ~~ bg ' / l1~ ~ f.S' i'Y~~1.t (~ ll~3o/i'~... ^" I ~ ~~~ --i '.~" ~~ ~ f Ij~ cn ~ w :x~ ~; ~~' ~ -„ .~ ~..F ~, •pa "4..,.. .~ ~ _..{. i SHERIFF'S OFFICE OF CUMBERLAND COUNTY my R Anderson,neriff Jody S Smith Chief Deputy 7013 Mi Y 23 PIN 2: 13 Richard W Stewart r'UMBERLANI l:Jj 1 j> P�P#NSYLdAIA, Solicitor 1 Ability Recovery Services, LLC Case Number vs. 2012-4779 Louis Larson SHERIFF'S RETURN OF SERVICE 09/07/2012 02:16 PM - Elizabeth Muller, Deputy , being duly sworn according to law, states that on September 07, 2012 at 2:16 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: Louis Larson at 218 Roxbury Road, Shippensburg Borough, 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 09-11-12. 09/14/2012 On September 14, 2012, at 1045 hours, a property claim was filed by Deborah Larson. All parties notified by mail this date. 09/26/2012 Reference is made to Property Claim dated 09-14-12 entered by Deborah J. Larson. Ronny R. Anderson, Sheriff, has determined that the claimant, Deborah J. Larson, in the above mentioned property claim, is the owner of the property set forth in the claim. 10/08/2012 No objections filed in this case. Refunding $25.00 to claimant. Writ to remain open as property still remains on levy. 10/09/2012 Objections filed with Prothy in this case;we received no notification. 11/09/2012 Letter received from Attorney Mulligan inquiring as to the status of the Objections. Checked with prothonotary's office; they received the objections and filed same with no action. They were going to pull the file and forward to Court Administration to schedule a hearing. 11/15/2012 ORDER And now, this 15th day of November 2012, hearing on the Plaintiffs Objections to Sheriffs Determination is set for Thursday, November 29, 2012, at 3:00 p.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. By The Court, Kevin A. Hess, P.J. 11/30/2012 ORDER OF COURT And now, this 29th day of November, 2012, after hearing, the objection of the plaintiffs,Ability Recovery Services, LLC, to the determination that the Sheriff made September 24, 2012, is dismissed. By the Court, Kevin A. Hess, P.J. 05/23/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney. �y Sr0 I / ��• :GU^ii` uitc ahNIf`.TGI r,OSOfi.i...-. i RIFF COST: $117.15 SO ANSWERS, May 23, 2013 RON R ANDERSON, SHERIFF ;cu ciut�n.°;ti,ie:oscit :..,,. i IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ; rri ABILITY RECOVERY SERVICES, LLC : - r_- P.O. BOX 4031 : CIVIL ACTION -� WYOMING, PA 18644 NO.: 12-4779-CV -c, CD VS CD W.> __ DEFENDANT ' LOUIS LARSON • 218 ROXBURY ROAD • SHIPPENSBURG, PA 17257 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: PLEASE SATISFY JUDGMENT AS THIS HAS BEEN SATISFIED IN FULL. PLEASE SEND NOTICE TO ALL PARTIES PURSUANT TO PA R.C.P. 236. Date: 51iJi5 �i Gam.. -r s T. Mulligan, Jr., Esq. P... Box 4031 Wyoming, PA 18644 (570) 207-1892 ext. 235 PAID # 51794 In House Counsel for Plaintiff JU GMENT SATISFIED NOW, THIS DAY OF Lt , 2013, THE JUDGMENT HEREIN HAS BEEN MARKED SATISFIED. NOTICE GIVEN TO ALL PARTIES PURSUANT TO Pa. R.C.P. 236. PROTHI OTA DATE: La h `2 B PUTY