Loading...
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 ~, _r.{ ~ ~ ~ -a ~=~ Cry ~" ~ ~,~ ~..,._ . 3 T? ' i, .~ C..~ ~ .~ ~-.. ~ ~ ~J C.:. • `• --f ~~ .: 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. ~" ~ l ' . DATE: ~ ~ $ ~ 3 AT O NEY FOR PLAIN IFF AT O NEY FOR PLAIN IFF NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 51794 ate} ~3~.as~ any ~~a~q~ ~1~~ h~¢ (~1~~ 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 . . f L/U S ~~/~ 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 , -/~~~ ~ ~i~. `~~ f~'q / ~,~[ f 3 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. (- .~M'~" (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 ~, ~ - °,~.: w ~' ... r~ z -~ ..... , Disposition ~ Dspo Sinn Date Default Judgmentfor.~iff .. ~P/i7/2012 ._; c~ .~ ; -~- ~ 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 „, ~~ ~ O I iM 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 ~~~ 7y ~~ ~~ a~ 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 �� -" 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 ,sue j�L-�d1. ;c)CountySLAe S?ienff.Teleosoft.inc.