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HomeMy WebLinkAbout12-7301IN 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. / ~, - ~.~I vs, NOTICE OF FILIN G JUDGMENT ELIZABETH HALLETT 57 MEADE DRIVE CARLISLE, PA 17013 ~~ c~ ~~ rn~ ~~ • ~r :U Cn~ Defendant -< ?' r „ PRAECIPE FOR ENTRY OF JUDGMENT ~''-' ~ c, TO THE PROTHONOTARY: ~,' e;~.L7~ ~~ 0 !"v"1 {'7 1 w A ,~- 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: OCTOBER 11, 2012 b. Amount: $ 5,400.36 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: 57 MEADE DRIVE, CARLISLE. PA 17013 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. 1 vti vU A 'T RNEY FOR PL INTIFF NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 51794 ADDRESS: P.O. Box 4031, Wyoming, PA 18644 ~:. _.~ -~-, f"rl - ~~, ~~ ~~ .~,_. :.~:. ~ i -~ _~ DATE: 11 z~ L e.~ ~rsz~Q ,~ ~ s~~s /Ve-~ri`v n-1~~ ff 1 IN THE COURT OF COMMON PLEAS ` ' ' :� (R OE t HU} o j . CUMBERLAND COUNTY;PENNSYLVANIA r; CIVIL DIVISION Q�T �' 14: L GUi8ERLAlDP CQUt7''r' PLAINTIFF PENNS YLVAN!A ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 : CIVIL ACTION WYOMING, PA 18644 • NO.: 2012-7301 DEFENDANT • ELIZABETH HALLETT • 57 MEADE DRIVE • CARLISLE,PA 17013 • PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: PLEASE BE KIND ENOUGH TO SATISFY JUDGMENT AS THIS MATTER HAS BEEN PAID IN FULL. PLEASE SEND NOTICE TO ALL PARTIES PURSUANT TO PA R.C.P. 236. Date: 1°111 113 i�,' 'V. �� tAY I Jame T. Mulligan, Jr., Esq. P. . ox 4031 Wyoming, PA 18644 (570) 207- 1892 ext. 235 PA ID# 51794 In House Counsel for Plaintiff JUDGMENT IS SATISFIED NOW, THIS a DAY OF 0 CJ, 2013, THE JUDGMENT HAS BEEN SATISFIED. NOTICE GIVEN TO ALL PARTIES PURSUANT TO Pa. R.C.P. 236. PRO ON R ' DATE: /b /3 .e 'q3 . DEPUTY 03%X\�a o att. Sdusio -79(49 COMMONWEALT!~ OF PENNSYLVANIA COUNTY OF CUMBERLA.~ND Notice of Judgment/Transcript Civil Case Mag. Dist. No: MDJ-09-2-01 MDJ Name: Honorable Paul M Fegley Address: 2260 Spring Road, Suite 3 Carlisle, PA 17013 Telephone: 717-218-5250 ABILITY RECOVERY SERVICES, LLC PO BOX 4031 WYOMING, PA 18644 Disposition Summary Docket No Plaintiff MJ-09201-CV-0000103-2012 ABILITY RECOVERY SERVICES, LLC ..._.. W_. __.. Judgment Summary Docket No: MJ-09201-CV-0000103-2012 Case Filed: 8/23/2012 NOV 2~ 2012 ~E1/i~Sfp /O//!+~ 2 Defendant Disposition Disposition Date Elizabeth Hallett Judgment for Plaintiff 10/11!2012 Participant Joint/Several Liability Individual Liability ABILITY RECOVERY SERVICES, LLC $0.00 $0.00 Elizabeth Hallett $0.00 $5,400.36 Am n $0.00 $5,400.36 _. Judgment Detail ~"Post Judgment) In the matter of ABILITY RECOVERY SERVICES, LLC vs. Elizabeth Hallett on 10/11/2012 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied nt Civil Judgment $0.00 $5,247.36 $5,247.36 Filing Fees $0.00 $153.00 $153.00 Grand Total: 55,400.36 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 JUDGMENTlTRANSCRIPT 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. r ~_ ~~ ~~ ~ Date Magisterial District Judge Paul M Fegley ~tl~^+ ~'~~ ~' ~"~Ixl ,lI4,~K ~*' OgA1 certi at is is a rue an correct copy o t e recur o t e procee i gs mg a lu g ~~ Date Magi terial Dist 'ct Judge ABILITY RECOVERY SERVICES, LLC V. Elizabeth Hallett MDJS 315 Page 1 of 2 Printed: /16/2012 12:01:31 PM ash 7~~~ 3~0 ~ 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. ELIZABETH HALLETT 57 MEADE DRIVE CARLISLE, PA 17013 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, ELIZABETH HALLETT, 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. j 1~ ~ Z Date In House Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 207-1892 Ext 235 SPECTFULLY SUBMITTED, ~v-~`" J e T. Mulligan, Esq. A ID#: 51794 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 ELIZABETH HALLETT 57 MEADE DRIVE CARLISLE, PA 17013 Defendant (X) Notice is hereby given that.a JUDGMENT in the above-captioned matter has been entered against you in the amount of $5,480.36 on OCTOBER 11, 2012 (X) A copy of all documents filed with the Prothongary/Cle~ Civ~ ivision i=ort of the within judgment is/are enclosed. ©~'ar~'rR~Cfvil Division By: Deputy If you have any questions regarding this Notice, please contact the filing party: Name: James T. Mulligan, Esq. P.TTY ID#: 51794 In House Attorney for Party: ABILITY RECOVERY SERVICES, LLC Address: PO Box 4031, WYOMING, PA 18644 Telephone: (855) 207-1892 Ext 235 CON~MONWEALTH OF PENNSYLVANIA ' COI~NTY OF: CUMBERLAND 09-2-01 MDJ Name: Hon. PAUL FE~LEY Address: 2280 SPRING ROAD SUITE 3 CARLISLE, PA 17013 Telephone: (717)218-5250 BUG 2 ~ 2012 CIVIL COMPLAINT PLAINTIFF: NAME and ADDRESS ~ ABlLlTY RECOVERY SERVICES, LLC ~ PO BOX 4031 WYOMING, PA 18644 ~ phone: (855) 207-1892 ~ VS. DEFENDANT: NAME and ADDRESS ~ ELIZABETH HALLETT ~ 57 MEADS DRIVE CARLISLE, PA 17013 L_ ~ Docket No.: ~ _ 10 r. ~'Z" Date Filed: 8 /?s3/!Z. -°.,. AMOUNT DATE PAID FILING COSTS $ / / POSTAGE $ I l Social security numbers and financial information SERVICE COSTS $ l I (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ I / account number must be established, list only the TOTAL $ 153.00 S l ,?~l / ~.Z 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 $ x.247.36 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): ELIZABETH HALLETT is indebted to CHASE BANK, USA credit card bearing account number XXXXXXXXXXXX8710 in the amount of $5,247.36 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES,LLC on DECEMBER 1, 2011 and the last payment was made on SEPTEMBER 11, 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 a penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. ~~ ~'i , - ( ignature of Plainti or Authorized Agent) The plaintiff's attorney shall file an entry of appearance with the magisterial district lsoaft 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 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 u�ti� 4f `tCur�r��r�. RONNY R.ANDERSON g RICHARD W.STEWART Sheriff s Solicitor U JODY S.SMITH Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 �m -0 rn —t/aC> %jo C April 18, 2013 r' , ;' , Ability Recovery Services, vs rn� Elizabeth Hallett Writ No. 2012-7301 Property Claim Determination To Whom It May Concern: Reference is made to.Property Claim dated April 8, 2013, entered by Paul H. Haut, Jr., Writ of Execution No. 2012-7301, Ability Recovery Services, LLC vs. Elizabeth Hallett. Ronny R. Anderson, Sheriff, has determined that the claimant, Paul H. Haut, Jr., in the above mentioned property claim, is the owner.of the property set forth in the claim. So Answers: R . Anderson, Sheriff cc / James t. Mulligan, Jr., Attorney for Plaintiff Paul H. Haut, Jr., Claimant Elizabeth Hallett, Defendant NOTICE OF PROPERTY CLAIM Ability Recovery Services, LLC In the Court of Common Pleas Cumberland County, Pennsylvania VS Elizabeth Hallett No. 2012-7301 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Paul H. Haut, Jr., claiming property listed therein. Unless an appraisal of the property is requested within(10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 04-09-13 1_ 1516 of Cumberland County B s° r L Cc James T. Mulligan, Jr., Attorney for Plaintiff Paul H. Haut, Jr., Claimant Elizabeth Hallett, Defendant PROPERTY CLAIM In the Court of Common Pleas of Cumberland County,Pennsylvania A�o I'tv 2�`ccaue2Y s��r�v rtes t,L� Writ No. 110 '7 3 Q VS L•����,�,e iii �lr�L1.��' TO THE SHERIFF OF CUMBERLAND COUNTY,PENNSYLVANIA The property listed below and levied upon in this case is not the property of the defendant,but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE 3c3- 0z:) Q-z) oco 3 I5N) � s Wob&"') I V 'LF1��,e(''If SLRf us-u( L G- I -1V� P Ave/t- snN),-/ l (3��� C0 O.<yo 3 T'A ij Ea C)t S to I Q less �V sIAJ Q5� THE CLAIMANT OWCAINED TITLE TO THE PROPERTY AS FOLLOWS: Qe�"r Date H"g^ Cla' State.of Pennsylvania: County of Cumberland being duly sworn according to law,deposes and says that the above list in the property claim are correct and true. Sworn subscribe to before me s y of Z NOTARIAL SEAL Claimant CLAUDIA A. BREWBAKER,NOTARY PUBLIC u tic Carlisie Boro,Cumberland County My Commission Expires April 4,2017 <p Q-3' s ,--% , cz-p --t4 tv Yf ) 5 j001 �L,/rn --yaril I aq , -----------------T \4 (YI pow.rah C> C7/7 90 9—Q r 171 Q-Q Ol <�ko . Q Is CD �Ml 0-?Lf �4�) -� 0 c Ao zo -ra N S t d ra MISC. f fvQ GoIS { �E CC>10 RALC jryn 1�i c, i rye. 5 t j p , Jj 140,I ,I a� �I �� d - ate I r ( a I� I. 'I i �I 3 li �((I I� IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA c� w CIVIL DIVISION „ w '7C-t J first 3 cY: PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 o WYOMING, PA 18644 c:� 3 NO.: 2012-7301 VS. DEFENDANT ELIZABETH HALLETT 57 MEADE DRIVE CARLISLE, PA 17013 NOTICE, OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby, given that on October 15, 2013, 2013, at 9:30 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 busire-s 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 m t M 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: L? 13 Respectfully Submitted, J s T. Mulligan, Jr., sq. P i # 1 51794 In-House Counsel for Plaintiff 570-207-1892 ext. 235 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,my R Anderson • neriff , r C,114/be - z Jody S Smith ��I1 'r ^ { Chief Deputy t � l _i asW Richard W Stewart 1 1< ' °' ;; sr Solicitor FFCE �m t-ERIF¢ E1:%1 �'! '�`,.a �o1 Ability Recovery Services, LLC Case Number vs. Elizabeth Hallett 2012-7301 SHERIFF'S RETURN OF SERVICE 04/03/2013 08:32 PM -Jason Kinsler, Deputy , being duly sworn according to law, states that on April 03, 2013 at 8:32 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: Elizabeth Hallett at 57 Meade Drive, North Middleton Township, Carlisle, PA 17013, 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 April 4, 2013. 04/08/2013 On April 8, 2013, at 1626 hours, a property claim was filed by Paul Haut. All parties notified by mail April 9, 2013. 04/18/2013 Reference is made to Property Claim dated April 8, 2013, entered by Paul H. Haut, Jr., Writ of Execution No. 2012-7301,Ability Recovery Services, LLC vs Elizabeth Hallett. Ronny R.Anderson, Sheriff, has determined that the claimant, Paul H. Haut, Jr., in the above mentioned property claim, is the owner of the property set forth in the claim. 04/29/2013 No objections filed in this case; refunding $25.00 back to claimant. Property DOES remain. 10/28/2013 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiffs attorney as a payment plan is in place. SHERIFF COST: $108.58 SO ANSWERS, October 28, 2013 RONR ANDERSON, SHERIFF S cc' -67 37) 4-L// 097 y4'(