HomeMy WebLinkAbout13-0405IN 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.
KATHRYN BUNK
616 N. FRONT STREET
LEMOYNE, PA 17043
Defendant
Docket No. 1 ~ ~ -/ `~
NOTICE OF FILING
JUDGMENT
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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.
OOther (please describe)
---------- ---------- --
a. Date of Instrument: DECEMBER 17, 2012
b. Amount: $ 12,185.87
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: 61 N FRONT STREET,
LEMOYNE, PA 17043
4. Please give notice to the parties pursuant to Pa.R.C.P. 236.
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DATE: ~ ~ $ ~ 3
AT O NEY FOR PLAIN IFF
AT O NEY FOR PLAIN IFF
NAME: James T. Mulligan, Esq.
ATTORNEY ID NO: 51794
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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.
KATHRYN RUNK
616 FRONT STREET
LEMOYNE, PA 17043
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, KATHRYN RUNK , 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 oY~iigation 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.
SPECTFULLY SUBMITTED,
Date J me T. Mulligan, Esq.
T ID#: 51794
In House Attorney for Plaintiff
PO Box 4031., Wyoming, PA 1.8644
(855) 207-1892 Ext 235
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COLfNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL DIVISION
ABILITY RECOVERY SERVICES, LLC
P.O. BOX 4031 .
WYOMING, PA 18644 .
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Plaintif Docket No. ~ ,~'
vs. NOTICE OF FILING
,. JUDGMENT
KATHRYN RUNK
616 N. FRONT STREET
LEMOYNE, PA 17043
Defendant
(X) Notice is hereby given that a JUDGMENT in the above-captioned matter has been
entered against you in the amount of $12,185.87 on DEC BE 7, 2
(X) A copy of all documents filed with the Prothonotary/C k, Ci iv' in supp
of the within judgment is/are 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
ddress: PO Box 4031, WYOMING, PA 18644
Telephone: (855) 207-1892 Ext 235
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CUMBERLAND
Magisterial
09-3-04
MDJ Name: Hon.
JUDGE CORREAL
Address: 5275 EAST TRINDLE ROAD
SUITE 110
MECHANICSBURG, PA 17050
Telephone: (717)768-3312
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
~ KATHRYN RUNK ~
511 RITTENHOUSE SQUARE ~~ ~~~ ,
MECHANICSBURG, PA 17050 , -/~~~
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Docket No.: C ~' 3159 °'? r ~ dLJHz
Date Filed: / ° /~ o~ o / ~" ~
AMOUNT DATE PAID
FILING COSTS $ ~Y3 ~° l ~~ l ~~
POSTAGE $ ~ ' ° ~ ~V l ~~ l ~~ Social security numbers and financial information
SERVICE COSTS $ ~•~ ft / ~ lI ~ (e.g. PINS) should not be listed. If the identity of an
CONSTABLE ED. $ C~' j J l ~ 11 ,~- account number must be established, list only the
TOTAL $ ~ b ~ ~~ l , i l , I- last four digits. 204 Pa.Code §§ 213.1 - 293.7.
I
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):
KATHRYN RUNK is indebted to CHASE BANK USA credit card bearing account number XXXXXXXXXXXX8658 in
the amount of $12,000.00 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES,LLC
on DECEMBER 1,2011 and the last payment was made on SEPTEMBER 6, 2009.
I, JAMES T. MULLIGAN. JR. 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.
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(Sig ature of Plaintiff or Authorized A nt)
The plaintiff's attorney shall file an entry of appearance with the magisterial district co ursuant 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
C~MMOIVWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil
COUNTY OF CUMBERLAND
` Case
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
PO Box 4031
Wyoming, PA 18644
Disposition Summary
Docket No
MJ-09304-CV-0000359-2012
Judgment Summary
Participant
Ability Recovery Services, LLC
Kathryn Runk
Plain iff Defendant
Ability Recovery Services, LLC Kathryn Runk
JointlSeveral Liability Individual Liability
$0.00 $0.00
$0.00 $12,185.87
Ability Recovery Services, LLC
v.
Kathryn Runk
Docket No: MJ-09304-CV-0000359-2012
Case Filed: 10/11 /2012
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Disposition ~ Dspo Sinn Date
Default Judgmentfor.~iff .. ~P/i7/2012
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Amount
$0.00
$12,185.87
Judgment Detail ("Post Judgment)
In the matter of Ability Recovery Services, LLC vs. Kathryn Runk on 12/17/2012 the judgment was awarded as follows
Judgment Component JoinUSeveral Liability Individual Liability Deposit Applied Amount
Civil Judgment $0.00 $12,000.00 $12,000.00
Filing Fees $0.00 $143.00 $143.00
Costs $0.00 $6.00
$6.00
Costs $0.00 $5.00
$5.00
Server Fees $0.00 $31.87
$31.87
Grand Total: $12,185.87
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.
ExCEp'r pc nTHER~nncE P!?Ol~!ncn IN THE RULES OF CI`lIL °ROCEC:;R:= F^Fi "11AGISTERIAL DISTRICT JL'CGES, IF THE JUCGI'r9EP3T
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.
Date
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Senior Magisterial District Judge Paula P. Correal ~"'~:~.;~'-°''~ ~:,'
I certi y that t is is a true and correct copy o t e record o t e procee mgs ntai ing t e ludg
Date M gisterial District dge
MDJS 315 Page 1 of 2 Printed: 12/18/2012 11~34:51AM
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
.onny R Anderson
Sheriff r
Jody S Smith
t0ir THE PRO THOmclTA, �'
Chief Deputy 4 ,
Richard W Stewart
2013 MAR 27 PM 3 10
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Solicitor OrfCE OF TmE SAERIFF
("UMBERLQND COUNT-Y
PUBS YLVA NI A
Ability Recovery Services, LLC Case Number
v
Kaths.ryn Runk 2013-405
SHERIFF'S RETURN OF SERVICE
03/06/2013 05:15 PM- Ryan Burgett, Deputy , being duly sworn according to law, states that on March 06, 2013 at
5:15 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:
Kathryn Runk at 616 N Front Street,Wormleysburg Boroughs Wormleysburg, PA 17043, informed
Defendant of contents of same and levied upon personal prVerty as directed. Postcard and copy of levy
mailed to attorney and letter mailed to defendant on March 8, 2013.
03/26/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, staters this writ of execution is
returned STAYED. Defendant filed for Chapter 7 bankruptcy; docket# *,-01523.
SHERIFF COST: $79.22 SO ANSWERS,
March 26, 2013 RONRrY R ANDERSON, SHERIFF
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