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HomeMy WebLinkAbout13-4295 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 / C� Plaintiff Docket No. / '5" VS. NOTICE OF FILING JOHN LAWLER JUDGMENT 607 GATES LANE ENOLA, PA 17025 -'0 ) �- Defendant 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. () Other (please describe) --------------------------------- Date of Instrument: JUNE 4, 2013 b. Amount: $ 9,455.15 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 1 hereby certify that the residence of the Defendant is: 607 GATES LANE, ENOLA, PA 17025 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. AT O EY FOR PLAINY4F DATE: 1 �� NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 5179 nS a-� GY I jZff aR39 i� U �C 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. JOHN LAWLER 607 GATES LANE ENOLA, PA 17025 Defendant(s) AFFIDAVIT OF NON - MILITARY SERVICE 1, James T. Mulligan, Esq., Attorney for Plaintiff, state that to the best of my knowledge, information and belief, that the Defendant, JOHN LAWLER, 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, Dat d Ja es . Mulligan, Esq. AT Y ID #: 51794 In House Attorney for Plaintiff PO Box 4031, Wyoming, PA 18644 (855) 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 Docket No. / ✓ -�a� G� VS. NOTICE OF FILING JUDGMENT JOHN LAWLER 607 GATES LANE ENOLA, PA 17025 Defendant (X) Notice is hereby given that a JUDGMENT in the above - captioned matter has been entered against you in the amount of 9,455.15 on JUNE 4, 2013 (X) A copy of all documents filed with the Prothonota sion in su o of the within judgment is /are enclosed. a�l Prot onotary /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 i COI`)j�IONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -1 -03 Ability Recovery Services LLC MDJ Name: Honorable Richard S. Dougherty V. Address: 98 South Enola Drive, Suite 1 John Lawler Enola, PA 17025 Telephone: 717- 728 -2805 Ability Recovery Services LLC Docket No: MJ- 09103 -CV- 0000048 -2013 P. O. Box 4031 Case Filed: 3/11/2013 Wyoming, PA 18644 , - JUN 2013 Disposition Summary Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09103 -CV- 0000048 -2013 Ability Recovery Services LLC John Lawler Default Judgment for Plaintiff 06/04/2013 Judgment Summary Participant Joint /Several Liability Individual Liability Amount Ability Recovery Services LLC $0.00 $0.00 $0.00 John Lawler $0.00 $9,455.15 $9,455.15 Judgment Detail ( *Post Judgment) In the matter of Ability Recovery Services LLC vs. John Lawler on 6/04/2013 the judgment was awarded as follows: Judament Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $9,269.11 -$9,269.11 Costs $0.00 $186.04 $186.04 Grand Total: $9,455.15 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. 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. 1 JUN 42013 1 1 / Date gisterial District dg ar . Dougherty, o, certify that this is a true and correct copy of the record of the proceedingy proceeding containing Lilt! lu nt. JU L 08 201 �2,5r Date gi istri J ge MDJS 315 Page 1 of 2 Printed: 06/05/2013 10: 7:59AM 7 �'77e , f COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT • Magisterial District Number: PLAINTIFF: NAME and ADDRESS 09 -1 -03 MDJ Name: Hon. ABILITY RECOVERY SERVICES,LLC RICHARD S. DOUGHERTY, JR. P O BOX 4031 Address: 98 SOUTH ENOLA DRIVE WYOMING, PA 18644 SUITE 1 PHONE NO: (855) 207 -1892 ENOLA, PA 17025 VS. Telephone: (717)728 -2805 DEFENDANT: NAME and ADDRESS I— JOHN LAWLER 607 GATES LANE ENOLA, PA 17025 L- -I Docket No.: l� y'— �— 1 3 Date Filed: AMOUNT DATE PAID FILING COSTS $ jq(,r, 6 (,) POSTAGE $ 1 l / Social security numbers and financial information SERVICE COSTS $ aa, 5� I l (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ account number must be established, list only the TOTAL $ / Q% D l l last four digits. 204 Pa. Code §§ 213.1- 213.7. Pa.R.C.P.D.J. No. 206 sets f orth those costs recoverable by the prevailing party. TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 9.269.11 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): JOHN LAWLER is indebted to CITIBANK SOUTH DAKOTA(WEST MARINE COBRAND CONSUMER) bearing credit account number XXXXXXXXXXXX4784 in the amount of $ 9,269.11 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES, LLC.,on SEPTEMBER 4, 2012 and last payment was made on FEBRUARY 14, 2010. 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. y� (Si nature of Plaintiff or Auth ed Agent) The plaintiffs attorney shall file an entry of appearance with the magisterial district 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 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 Ability Recovery Services LLC Docket No.: MJ- 09103 -CV- 0000048 -2013 V. John Lawler Participant List {� e Plaintiff(s) cn y� Ability Recovery Services LLC -mot P. O. Box 4031 K - C3 Wyoming, PA 18644 Defendant(s) John Lawler R 607 Gates Lane Enola, PA 17025 Complainant's Attorney(s) James T. Mulligan Jr., Esq. PO Box 4031 Wyoming, PA 18644 MDJS 315 Page 2 of 2 Printed: 06/05/2013 10:47:59AM 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.:13-4295-CV Vs. JOHN LAWLER E.D. 607 GATES LANE ENOLA,PA 17025 Defendant BELCO COMMUNITY CREDIT UNION Cn 5304 CARLISLE PIKE CD MECHANICSBURG,PA 17050 <(D t-'; _ Garnishee PRAECIPE FOR WRIT OF EXECUTIONt 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 John Lawler, Defendant;and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant,John Lawler; (3) and enter this writ in judgment index (a) against John Lawler,Defendant,and (b) against Belco Community Credit Union,as garnishee,as a lis pendens against real property of the defendant in the name of garnishee as follows: n/a JUDGMENT:$9,455.15 INTEREST:$111.60 PROTHONOTARY:RY:$$ SHERIFF: $ TOTALS RESPECTFULLY SUBMITED, S 3 C051­� p �, t /?� s air Dated ( Jam T.Mulligan,Jr.,Esq. 6.O Box 4031 Wyoming,PA 18644 PA ID#51794 � (866)760-6205 ext.235 LL In-House Counsel for Plaintiff 020 �� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION-LAW Plaintiff c� ABILITY RECOVERY SERVICES, LLC 'C P.O. BOX 4031 'j WYOMING, PA 18644 No.: 13-4295-CV crs �n u JOHN LAWLER -b C 607 GATES LANE 7 % ENOLA, PA 17025 © 37 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:_A(0 (0 Jz VMs T. Mulligan,Jr., Esq. PBox 4031 Wyoming, PA 18644 No.: 51794 In-House Counsel for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-4295 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due ABILITY RECOVERY SERVICES,LLC Plaintiff(s) From JOHN LAWLER,607 GATES LANE,ENOLA,PA 17025 (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 DEFENDANT,JOHN LAWLER (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: BELCO COMMUNITY CREDIT UNION,5304 CARLISLE PIKE,MECHANICSBURG,PA 17050 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$9455.15 Plaintiff Paid$ Interest $111.60 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: AUGUST 19,2013 David D.Buell,Prothonotary (;peal) '-P Deputy REQUESTING PARTY: Name :JAMES T. MULLIGAN,JR.,ESQ. Address:PO BOX 4031,WYOMING,PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 EXT.235 Supreme Court ID No.51794 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson wdLED-OFF ICE . 0 THE PROTHONOTARY, Sheriff �tr;5t#of t��rxntrc �*� Jody S Smith 2013 AUG 26 API N 01 Chief Deputy ,, Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICEOFTt,, S-KwRlfi= PENNSYLVANIA Ability Recovery Services, LLC Case Number vs. 2013-4295 John Lawler SHERIFF'S RETURN OF SERVICE 08/21/2013 02:20 PM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Jorge Anguiano,Assistant Manager, personally three copies of interrogatories together with three true and attested opie of the Writ of Execution and made the contents there of known to him. ILL AM CLIN , DEPUTY SO ANSWERS, a �C August 23, 2013 RbWN R ANDERSON, SHERIFF (c)CountySu!te Sheriff.To!eosok.i!?c. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA ABILITY RECOVERY SERVICES, LLC P. O. BOX 4031 WYOMING, PA 18644 Plaintiff NO.: 13-4295-CV vs. JOHN LAWLER 607 GATES LANE ENOLA, PA 17025 a` Defendant BELCO COMMUNITY CREDIT UNION C= 5304 CARLISLE PIKE - MECHANICSBURG, PA 17050 Garnishees PRAECIPE FOR JUDGMENT BY ADMISSION AGAINST GARNISHEE, BELCO COMMUNITY CREDIT UNION, ONLY TO THE PROTHONOTARY: Kindly enter Judgment By Admission for Plain? f Ability Recovery Services, LLC against Belco Community Credit Union, only, in the amount of$516.52,pursuant to said Garnishee's Answer to Plaintiff, Ability Recovery Services, LLC's Interrogatories in Attachment hereto, and index same in the judgment index. Please send a copy of the judgment to all parties, pursuant to Pa. R.C.P. 236. $[(,.sopa ATrl 2� X455(05 JVAce' Mail 1 RESPECTFULLY SUBMITTED DATE: �_�ti.. J es . Mulligan, Jr., Esquire P.O. Box 4031 Wyoming,PA 18644 PA ID# 51794 (866) 760-6205 ext. 235 In House Counsel for Plaintiff JUDGMENT Now this I day of ZVe 2013, Judg.nznt is entered for Plaintiff, Ability Recovery Services,LLC, against Be co Community Credit Union, only, in the amount of $516.52,which is indexed in the judgment index. A copy of said judgment is sent to all parties, per Pa. R.C.P. 236. Prothonotary By: Deputy r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Lmo. 13-4295-CV VS. JOHN LAWLER E.D. 607 GATES LANE ENOLA,PA 17025 Defendant and ����`��� BELCO COMMUNITY CREDIT UNION 5304 CARLISLE PIKE CEP ®4 MECHANICSBURG,PA 17050 Garnishee PLAINTIFF'S INTERROGATORIES TO GARNISHEE r TO BELCO COMMUNITY CREDIT UNION (Garnishee): You are required to file answers to the following interrogatories within thirty (30) days after service upon you. Failure to do so may re silt in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? What is the total amount available in account(s)? V—UD 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant? 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? S S 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent, and, if so, what was the consideration therefore? 6. At any time after you were served did you pay,transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? 7. If you are a bank or other.financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemp ' n and tke entity electronically depositin those funds on a recu irlg bas's. ��, 8. If yo h fn nScia imserved or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8 3? If so, identify each account. DATE: 8-16-13 J s T. Mulligan, Jr., ENquire P. Box 4031 �,,y oming,PA 18644 PA ID#51794 (866)760-6205 ext.235 Attorney for Plaintiff r v VERIFICATION Understanding that false statements herein are made subject to the penalties of 18 PA.C.S. §4904,Unsworn Falsification to Authorities, I verify that I am yQ,l Garnishee in the above matter and that, after inquiry, the facts set forth in the egoing Answers to Interrogatories are true, correct, and cort�pl:to to the best of my knowledge, information, an belief. DATE: R Wo -"�'--��r Signature SHERIFF'S OFFICE OF CUMBERLAND COUNTY rl !L E j Ronny R Anderson 0 '11 1FE P R ji' q 0� Sheriff 't Jody S Smith r. 2013 SEP I •AM 9: Chief Deputy i15;Q1 Richard W Stewart "11"ERLAND COUNTY Solicitor OF;XE OF,THE�44LRIFr PENNSYLVANIA Ability Recovery Services, LLC Case Number vs. 2013-4295 John Lawler I SHERIFF'S RETURN OF SERVICE 08/21/2013 02:20 PM-William Cline, Deputy,who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Jorge Anguiano, Assistant Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to him. 09/16/2013 Received Claim for Exemption this date. Taken to Court Administration to schedule a hearing. 09/17/2013 Ronny R. Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is returned as STAYED at request of plaintiffs attorney. 09/17/2013 Service Withdrawn on personal property levy by Attorney. SHERIFF COST: $103.54 SO ANSWERS, September 17, 2013 RbNW R ANDERSON, SHERIFF (c)CrruntySuite Sheriff,Tole-osaft,Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION ' PLAINTIFF rn o ABILITY RECOVERY SERVICES, LLC : = --• P.O. BOX 4031 .� c,,, c ; WYOMING, PA 18644 • r- == • NO.: 13-4295-CV >o vs. : 57, DEFENDANT : y> JOHN LAWLER : 607 GATES LANE • ENOLA, PA 17025 and • • GARNISHEE • BELCO COMMUNITY CREDIT UNION : 5304 CARLISLE PIKE MECHANICSBURG, PA 17050 • PRAECIPE TO DISCONTINUE ATTACHMENT AND SATISFY JUDGMENT AGAINST BELCO COMMUNITY CREDIT UNION, GARNISHEE ONLY TO THE PROTHONOTARY: Kindly mark the attachment and satisfy judgment against Garnishee, Belco Community Credit Union, Garnishee only, discontinued, and give notice to all parties pursuant to Pa. R.C.P. 236. Date: \30\IS 46".'4—es T. Mull: q. gan, Jr., -� 61•'56 In-House Counsel for Plaintiff QW` a, P.O. Box 4031 Wyoming, PA 18644 et t42o Oo?9?9 l (866) 760-6205 ext. 235 DISCONTINUANCE AND SATISFACTION OF JUDGMENT Now, this _2 day of OCA"', , 2013, the attach;Pnt against Belco Community Credit Union, Garnishee only, is discontinued and judgment is satisfied. Notice is given to all parties pursuant to PA. R.C.P. 236. Prothonotary ' By: Deputy IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF , ABILITY RECOVERY SERVICES, LLC -. P.O. BOX 4031 r° Fri-: WYOMING, PA 18644 NO.: 13-4295-CVO DEFENDANT c -� =C:1 . JOHN LAWLER 607 GATES LANE ENOLA,PA 17025 NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on February 5, 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). x` M 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). 15. All documents showing any debts owed to you or to any business in which you have any i 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: )Z L7 17 Respectfully Submitted, Q(� --r- �A At�� J s T. Mulligan, Jr., ES Y. a d# 51794 n-House Counsel for Plaintiff 570-207-1892 (ext. 235) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 vs. JOHN LAWLER 607 GATES LANE ENOLA, PA 17025 Plaintiff J.D. No.: 13- 4295 -CV Defendant BELCO COMMUNITY CREDIT UNION 5304 CARLISLE PIKE MECHANICSBURG, PA 17050 Garnishee TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION E.D. Issue writ of execution on the above matter, directed to the Sheriff of Cumberland County (1) against John Lawler, Defendant; and (2) against Belco Community Credit Union, garnishee; and (3) and enter this writ in judgment index (a) against John Lawler, Defendant, and (b) against Belco Community Credit Union, as garnishee, as a lis pendens against real property of the defendant in the name of garnishee as follows: n/a JUDGMENT: $9,455.15 INTEREST: $444.85 PROTHONOTARY: $ SHERIFF: $ TQTALL I. %``1.°c'-1)A CLi n.aS (2;12.00;: RE PECTFULLY SUBMIT es T. Mulligan, Jr., Esq . Box 4031 yoming, PA 18644 PA ID # 51794 (866) 760 -6205 ext. 235 In -House Counsel for Plaintiff ej._4 scADus -�� 3c,L1a 3 EY 3%-&--4- THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net ABILITY RECOVERY SERVICES, LLC Vs. JOHN LAWLER WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13 -4295 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against JOHN LAWLER, 607 GATES LANE, ENOLA, PA 17025 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of-the defendant (s) not levied upon in the possession of BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA 17050GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $9,455.15 Plaintiff Paid Interest $444.85 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $218.79 Date: 4/10/14 (Seal) 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 Supreme Court ID No. 51794 David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of Cir+iibc,rt7 OFFICE OF THE S! E,RIFF 2014 APR 17 PH 3: 20 CUMBERLAND COUNTY PENNSYLVANIA Ability Recovery Services, LLC vs. Case Number John Lawler 2013 -4295 SHERIFF'S RETURN OF SERVICE 04/14/2014 Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Colleen Dean, Member Service Representative, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on April 15, 2014 to John Lawler at 607 Gates Lane, Enola, PA 17025. April 15, 2014 CcuntySui:e Shenti,, Te'eoseft, inc. SO ANSWERS, RONR ANDERSON, SHERIFF ABILITY RECOVERY SERVICES, LLC, Plaintiff v. JOHN LAWLER Defendant v. BELCO COMMUNITY CREDIT UNION, Garnishee Cauntp of Cumberianb IN THE COURT OF COMMON PLEAS OFTHE NINTH JUDICIAL DISTRICT 2013-04295 CIVIL ACTION IN RE: CLAIM FOR EXEMPTION ORDER OF COURT AND NOW, this fi3 day of May 2013, upon review of the Claim for Exemption filed by John Lawler, Defendant is entitled to the $300.00 statutory exemption by law. Although Defendant did not claim an exemption for his Social Security benefits deposits in the amount of $1500.00, the Court, sua sponte, recognizes that the Social Security Act provides an exemption from attachment and garnishment for moneys paid as benefits. It is ORDERED and DIRECTED that Belco Community Credit Union shall release for Defendant's use, on a monthly basis, the directly deposited Social Security benefits of Defendant. All other accounts in/or deposits to Belco Community Credit Union, other than the monthly Social Security benefits direct deposits, remain subject to the garnishment of 10 April 2014. Distribution List: Aames T. Mulligan, Esq. ,./john Lawler Z3elco Community Credit Union CVO/WA-ISO L44111 Ot4144° BY THE COURT, Thomas . Placey C.P.J. 09/ RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy tv of OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 April 25, 2014 Cumberland County Court Administration 1 Courthouse Square Carlisle, PA 17013 RICHARD W. STEWART Solicitor Enclosed please find a Claim for Exemption, pertaining to Cumberland County Civil Case Number 13-4295, filed by John Lawler, which was received in the Cumberland County Sheriffs Office on this date. Please note that this pertains to a bank garnishment ONLY and the defendant is already entitled to a $ 300.00 statutory exemption. If a hearing is scheduled, please forward a copy of the Notice of Hearing to my attention in the Sheriffs office, however it is the Court's responsibility to notify all parties involved. Thank you for your consideration to this matter. Sharon R. Lantz Staff Assistant Involved Parties: James T. Mulligan, Attorney for Plaintiff James T. Mulligan, Jr., Esquire PO Box 4031 Wyoming, PA 18644 John Lawler, Claimant 607 Gates Lane, Enola, PA 17025 717-798-3940 : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA WRIT NO.2 0 1 3- `f l 1 , CIVIL TERM CLAIM FOR EXEMPTION To the Sheriff: I, the above named. defendant, claim exemption of property from levy, or attachment: I. From my personal property in my possession which has been levied upon, (a) I desire that my $300 statutory exemption be (i) set aside in kind (specify property to be set aside in kind): J -27 teit�<� Ti`/ / h",✓f 4e/.,.), S .7 ee do ' 7t7, / /' 74-1d1 72. -4. 4 viz 0.v (ii) paid in cash following the sale ofthe property levied upon; or (b) I claim the following exemption (specify property and basis of exemption): - - ii,/ l/ iG ✓ 6 leifrj i zoo/ ✓ O 4-5 � v � �✓ :v, �- j b 0 G �` - / 2. From my property chm the possession of a thin party, I claim the following exemptions: (a) my $300 statutory exemption: ❑ in cash ❑ in kind (specify property): 767 0 .7:,i,-7•...5/7/ r- (b) Social Security benefits on deposit -in the amount of $ / 6- 0 (7 • • (c) other (specify amount and basis of exemption): I request a prompt court hearing to determine the exemption: Notice of the hearing of the hearing should be given to me at: P17. 4 - -1 // / o 7 64 A- d/U Address Et) • C4 /74 /7o2S- 7/7 lies 3,See Telephone Number I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ! 7- THIS CLAIM TO BE FILED WITH THE _OFFICE OF THE SHERIFF OF CUMBERLAND COUNTY: CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6390 i Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Clupb OFFICE OFTltS SHERIFF + L.`�� E!� ilia. E._ .t'ti 1ui5JM! i2 I(-1 3 1J CUMBE LAN() COUNTY PENNSYLVANIA Ability Recovery Services, LLC vs. John Barry Lawler, Jr Case Number 2013-4295 SHERIFF'S RETURN OF SERVICE 04/14/2014 Ryan Burgett, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Belco Community Credit Union, 5304 Carlisle Pike, Hampden Townsihp, Mechanicsburg, PA 17055, Cumberland County, by handing to Colleen Dean, Member Service Representative, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on April 15, 2014 to John Lawler at 607 Gates Lane, Enola, PA 17025. 04/25/2014 Claim for exemption filed this date; taken to Court Administration. NOTE: Paperwork was brought to us by someone from the Cumberland County Bar Association - paperwork was mailed to their office instead of our office. 05/27/2014 ORDER OF COURT And now, this 27th day of May 2013 (should have been 2014), upon review of the Claim for Exemption filed by John Lawler, Defendant is entitled to the $ 300.00 statutory exemption by law. Although Defendant did not claim an exemption for his Social Security benefits deposits in the amount of $1500.00, the court, sua sponte, recognizes that the Social Security Act provides an exemption from attachment and garnishment for moneys paid as benefits. It is ordered and directed that Belco Community Credit Union shall release for Defendant's use, on a monthly basis, the directly deposited Social Security benefits of Defendant. All other accounts in/or deposits to Belco Community Credit Union, other than the monthly Social Security benefits direct deposits, remain subject to the garnishment of 10 April 2014. By The Court, Thomas A. Placey, Judge 01/08/2015 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $89.26 SO ANSWERS, January 08, 2015 RONNY R ANDERSON, SHERIFF (c) CountySuite Sherif(, T eieosoff, Ino. aii9939, 3/5-5-9 t THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net ABILITY RECOVERY SERVICES, LLC Vs. JOHN LAWLER WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13-4295 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against JOHN LAWLER, 607 GATES LANE, ENOLA, PA 17025 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of BELCO COMMUNITY CREDIT UNION, 5304 CARLISLE PIKE, MECHANICSBURG, PA 17050GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee 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; (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $9,455.15 Interest $444.85 Attorney's Comm. % Attorney Paid. $218.79 Date: 4/10/14 (Seal) 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 Supreme Court ID No. 51794 Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs ai,14(,eLI ait David D. Buell, Prothonotary MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law F In Testimony whereof, hand TRUE- COP FROM RECORDI here unto set my and the seal of said Court at CarUsle2 Pa; This tb day of Prothonotary -1'z 2