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Home My WebLink About13-6699 r . - ' - 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 U Itj Plaintiff Docket No. ) J " 6 VS. NOTICE OF FILING DOUGLAS MCNAUGHTON JUDGMENT 140 BIG SPRING TERRACE APT 5 NEWVILLE, PA 17241 Defendant 5 �a PRAECIPE FOR ENTRY OF JUDGMENT � C am: TO THE PROTHONOTARY: r� CD 1. Enter judgment on the attached: ,- ( ) Instrument confessing judgment or authorizing confession by an attorney at law op 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 1, 2013 b. Amount: $ 12,172.65 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 1 hereby certify that the residence of the Defendant is: 140 SPRING TERRACE, APT 5, NEWVILLE, PA 17241 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. o f — C� I - V "1 ATt9P,NEY FOR PLAINTI DATE: f 3 NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 51794 p1F r R 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. 1 VS. DOUGLAS MCNAUGHTON 140 BIG SPRING TERRACE APT 5 NEWVILLE, PA 17241 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, MCNAUGHTON 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, 4� // ) (�— ('� k X�� Dat d tTY s T. Mulligan, sq. 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 CUMBERLANDCOUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Docket No. VS. NOTICE OF FILING JUDGMENT DOUGLAS MCNAUGHTON 140 BIG SPRING TERRACE APT 5 NEWVILLE, PA 17241 Defendant (X) Notice is hereby given that a JUDGMENT in the above - captioned matter has been entered against you in the amount of $12,172.65 on OC TO ER 1 2013 (X) A copy of all documents filed with the Prothonotary /Cle , Civi ivisioh 'n suppo 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 Address: PO Box 4031, WYOMING, PA 18644 Telephone: (855) 207 -1892 Ext 235 low 1W "T COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -02 Ability Recover Services LLC MDJ Name: Honorable Vivian Cohick V. Address: 55 Penn Drive Douglas McNaughton Newville, PA 17241 Telephone: 717- 776 -3187 Ability Recover Services LLC Docket No: MJ- 09302 -CV- 0000174 -2013 P. O. Box 4031 Case Filed: 8/1/2013 Wyoming, PA 18644 Disposition Summary (cc_- cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09302 -CV- 0000174 -2013 Ability Recover Services LLC Douglas McNaughton Default Judgment for Plaintiff 10/01/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Ability Recover Services LLC $0.00 $0.00 $0.00 Douglas McNaughton $0.00 $12,172.65 $12,172.65 Judgment Finding j "Post Judgment) In the matter of Ability Recover Services LLC vs. Douglas McNaughton on 10/01/2013 the judgment was awarded as follows: Judgment Component JointlSeveral Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $12,000.00 $12,000.00 Costs $0.00 $172.65 $172.65 Grand Total: $12,172.65 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 JUDGMENTITRANSCRIPT 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 II I 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. ,Ith of p Date Magisterial District Judge Vivian Cohick cert ify that t is is a true and correct copy of e record of the proceedings conta ning t e lu gm t q -�3 . )1- Date Magisterial District Ju MDJS 315 Page 1 of 2 Printed: 1010112013 3:13:58PM .3,7 l Ability Recover Services LLC , . Docket No.: MJ- 09302 -CV- 0000174 -2013 V. Douglas McNaughton 2013 H 12 AM 114 Participant List GUMBERLANO COUNTY PENNSYLVANIA Plaintiff(s) Ability Recover Services LLC P. O. Box 4031 Wyoming, PA 18644 Defendant(s) Douglas McNaughton 140 Big Spring Terrace. Newville, PA 17241 Complainant's Attorney(s) James T Mulligan Esq. Jr., Esq. PO Box 4031 Wyoming, PA 18644 MDJS 315 Page 2 of 2 Printed: 10/01/2013 3:13:58PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CU MBERLAND CIVIL COMPLAINT Magisterial District Number: PLAINTIFF: NAME and ADDRESS 09 -3 -02 ' MDJ 'Narne: Hon. ABILITY RECOVERY SERVICES, LLC VIVIAN J. COHICK ' PO BOX 4031 Address: 55 PENN DRIVE WYOMING, PA 18644 NEWVILLE, PA 17241 phone: (855) 207 -1892 VS. Telephone: (717)776 -3187 DEFENDANT: NAME and ADDRESS F— DOUGLAS MCNAUGHTON 140 BIG SPRING TERRACE APT 5 NEWVILLE, PA 17241 Docket No.: CV / l� Date Filed: AMOUNT DATE PAID FILING COSTS $ POSTAGE $ / / SERVICE COSTS $ / / Social security numbers and financial information (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ l l account number must be established, list only the TOTAL $ 157.50 l l last four digits. 204 Pa. Code §§ 293.1 - 293.7. 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): DOUGLAS MCNAUGHTON is indebted to CITIFINANCIAL SERVICES( CITIFINANCIAL PLUS) bearing account number XXXXXXXXX3685 in the amount of $12,000.00 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES, LLC on JUNE 1, 2012 and the last payment was made on MARCH 29, 2011. 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. (Signature of Plaintiff or Authorized Agent) The plaintiffs attorney shall file entry of appearance with the magisterial district court 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ABILITY RECOVERY SERVICES,LLC .• P.O.BOX 4031 r-) ' WYOMING,PA 18644 • - -c- . -- Plaintiff J.D.No.:13-6699-CV =' �� , :, C=% vs. _ ,<C) 't? C.) .. DOUGLAS MCNAUGHTON E.D. 140 BIG SPRING TERRACE,#5 .• NEWVILLE,PA 17241 -"; Defendant .• PRAECIPE FOR WRIT OF EXECUTION(LEVY—PERSONAL PROPERTY1 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 Douglas McNaughton,Defendant;and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Douglas McNaughton; (a) and enter this writ in judgment index against Douglas McNaughton,Defendant JUDGMENT:$12,172.65 INTEREST:$202.00 PROTHONOTARY:$ SHERIFF: $ T TALLS RESPECTFULLY SUBMITED, 1 't tk-k *A 1 Dat d . es T.Mulligan,Jr.,Esq. , •.Box 4031 Wyoming,PA 18644 PAID#51794 (866)760-6205 ext.235 In-House Counsel for Plaintiff a . aS 6i- 1 ic 7 ?c) .ate 0._ ttif S /ri:? Rik 3 00 L1( a. Vc 1 OF 4( Tt4 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-6699 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 DOUGLAS MCNAUGHTON, 140 BIG TERRACE,#5,NEWVILLE,PA 17241 (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 THE DEFENDANT, DOUGLAS MCNAUGHTON. (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$12,172.65 Plaintiff Paid$59.75 Interest $202.00 Attorney's Comm. % Law Library$ SO Attorney Paid$ Due Prothonotary$2.25 Other Costs$ Date: 01/13/2014 _ _ David D. Buell,Prothonotary Deputy REQUESTING PARTY: Name : JAMES T. MULLIGAN,JR.,ESQUIRE Address: P.O. BOX 4031 WYOMING,PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 EX.235 Supreme Court ID No. 51794 �� t v of QCurrrherr� RONNY R.ANDERSON �' ,+Yv° RI b 7 ,_ CHARD W.STEWART Sheriff k4;;? ` �' f��,j � w , Solicitor JODY S.SMITH " Chief Deputy OFFICE OF THE SHERIFF One Courthouse Square, Room 303 m • Carlisle, Pennsylvania 17013 cn r —G -..t r— .Are March 6, 2014 ; Ability Recovery Services vs Douglas McNaughton Cumberland Co. Writ No. 13-6699 Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated February 24, 2014, entered by Bree- Anna Wickard, Cumberland County Writ No. 13-6699, Ability Recovrey Services vs Douglas McNaughton. Ronny R. Anderson, Sheriff, has determined that the claimant, Bree-Anna Wickard, in the above mentioned property claim, is the owner of the property set forth in the claim. So Answers: ' • ' . An erson, heriff cc Bree-Anna Wickard, Claimant Douglas McNaughton, Defendant James T. Mulligan, Jr., Attorney for Plaintiff 4 • NOTICE OF PROPERTY CLAIM Ability Recovery Services In the Court of Common Pleas Cumberland County, Pennsylvania VS Douglas McNaughton No. 2013-6699 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 Bree-Anna Wickard, 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 02-24-14 S er. of Cumberland County By Cc Bree-Anna Wickard, Claimant Douglas McNaughton, Defendant James T. Mulligan, Jr., Attorney for Plaintiff • PROPERTY CLAIM In the Court of Common Pleas of Cumberland County,Pennsylvania �� lifi eCC>v'e( S cvi (es, Ltc Writ No.go 13-Ca Co VS Pou Ics vA-gh tTh 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 ':B o \ SeC...-k-tollal So cc. bouk5rat- 034d 1 (00 ) -¢. - B Ccr\ vC5ec,k- bnc,(3 tJSedt /yrs C. $0 '-ab+ ac) Sim.3 0(-)5 Sc)' I✓ bovt5 hr. ()Sea 'bre Kevn 130 6 N1‘ 10.P+C P Cci mpu t 1b- :�n CUIPes 4 36 . e on s'.5' S c. \r1-cr— S� 14--e,,;k+-co - \CD a CGvOr vQ coo sit„ec- k blcckc N t s s Jec,-,sI u t-e,s (-es ■I IOC HE CLAIMANT OBTAINED TITLE TO TH4 PROPERTY AS FQLLOWS: O051C_S M` NC tytor. (St - brotvw_c_) S\ceps O( r Cot,Ch rYQ 1 rc p C c-t-`om C. rN C be c c1' C °fin 1-fl C( C" • _- • • fl• J Date - - 4 Claimant Do.., _�<<-•_� " State of Pennsylvania: County of Cumberland e two a Cid : C IC C f being duly sworn according to law,deposes and says that the above list in the property claim are correct and true. Swo.• and subt.,: ubofo - da} o_2i1.0 YM;i(1:Ae.,NOTARY PUBLIC Claimant 'ary Pu. IC : isle or.," berland County My Commission Expires April 4,2017 • \) ; 3ccee,1 co" So 5 rnGA% 3-cif v■lec- (-e Ss Q y U 39 1 v ;3(0 '' A, co 3 3O t,)6ad.e..r. wW GR 0..cound Us-% tea. 1per,Lh Shelkxn �� ;k-s (±4 She( U'2s) 00 eo.c_ A 30 _Lk ' 3 " -r-�, a �� 'GCQ -1ec,�-� 3o Lcs Q V hZ93i 4101 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT DOUGLAS MCNAUGHTON 140 BIG SPRING TERRACE, #5 NEWVILLE, PA 17241 NO.: 13- 6699 -CV —PI 11-Pi 2 `�r711; CU,a.�S r; :PM / 3 ,PJIA NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on May 9, 2014, at 11:00 AM, at the law offices of James T. Mulligan, Esq., 1 Montage Mountain Road, Suite A, Moosic, Pa 18507, 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 kind (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 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 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: Respectfully Submitted, s T. Mulligan, J d # 51794 In-House Counsel for Plaintiff 570-207-1892 (ext. 235) Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �°" "��"�"" " �" �~" " "�°�� " Flu -0:7F/�� THE PRDTHOHO'../�\ 78/6WA� 18 �� ; �� ... '~ ' '' � «` CUMBERLAND COUNTY Y PENNSYLVANIA Ability Recovery Services, LLC vs. Douglas Mc Naughton Case Number 2013-6699 SHERIFF'S RETURN OF SERVICE 01/23/2014 04:42 PM - Jamie DiMartle, Deputy . being duly sworn according to law, states that on January 23, 2014 at 4:42 PM hours, served the requested Wri of Execution Claim for Exemption Form and interrogatories by "personally" handing a true and attested copy to a person representing themselves to be the Defendant, to wit: Douglas McNaughton at 140 Big Spring Terrace, # 5, West Pennsboro Township, Newville, PA 17241, 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 January 24, 2014. 02/202014 Sheriffs sale scheduled for March 02/21/2014 07:04 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Sheriffs Sale Bill in the above titled action, upon the property located at 140 Big Spring Terrace, # 5, West Pennsboro Township, Newville, PA 17241, Cumberland County. 02/24/2014 On February 24, 2014, at 1105 hours, a property claim was filed by Bree-Anna Wckard. All parties notified by mail this date. 03/08/2014 Reference is made to Property Claim dated February 24, 2014, entered by Bree-Anna Wickard, Writ of Execution No. 2013-6699, Ability Recovery Services vs Douglas McNaughton. Ronny R Anderson, Sheriff, has determined that the claimant, Bree-Anna VVickard, in the above mentioned property ctaim, is the owner of the property set forth in the claim. 03/18/2014 No objections filed in this case; refunding $25.00 back to claimant. 03/18/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED per Pennsylvania Rules of Court 3206(c) pertaining to property claims. SHERIFF COST: $15072 SO ANSWERS, March 18, 2014 RONNYR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 : 13—tolag9 WYOMING, PA 18644 : NO.: X14.69li- DEFENDANT DOUGLAS MCNAUGHTON 140 BIG SPRING TERRACE, #5 NEWVILLE, PA 17241 NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on November 20, 2014, at 11:00 AM, at the law offices of James T. Mulligan, Esq., 1 Montage Mountain Road, Suite A, Moosic, Pa 18507, 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 kind (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 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 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: Respectfully Submitted, GAV-1 T. Mulligan, Jr., Esq. 51794 ouse Counsel for Plaintiff 570-207-1892 (ext. 235)