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13-6745
REORDER FROM PARTRIDGE WIRTH COMPANY 523 WYOMING AVENUE SCRANTON, PA 18509 344 -8514 OMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL COURT OF COMMON PLEAS FROM JUDICIAL DISTRICT DISTRICT JUSTICE JUDGMENT / COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice on the date and in the case mentioned below. O Q _ 3 Kw a wrr LL r K a. Of !T. e. OR xwxR or 0 AObR !! er A ► ►! T c)TT STAT[ ZIP COOK 06 ZV 6' CwTK O Jbo x KT 11 Z � Z 13 A.. CAI NO. RIOKATVR O► A ►RLLAKT OR X13 ATTORKRT O■ Aa RKT CV 20 - 0 l ? LT 20 This block will be signed ONLY when this notation is required u&W Pa. R.C.P.J.P. No. 10088. If appellant as Claima t (see Pa. R.C.P.'J.P. This Notice of Appeal, when received by the District Justice, will operate as No. 1001(6) in ion bef re District Justice, he a SUPERSEDEAS to the judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20) days after filing his NOT'),CE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of forrp to be used ONLY when appellant was DEFENDANT (see Pa. R.C.P.J.P. No. 1001(7) in action before District Justice. IF NOT USED, detach from copy of notice of appeal to be served upon appellee). PRAECIPE: To- Prothonotary Enter rule upon , appellee(s), to file a complaint in this appeal Name of appellee(s) (Common Pleas No. ) within twenty (20) days after service of rule or suffer entry of judgment of non pros. Signature of appellant or his attorney or agent RULE: To , appellee(s) Name of appellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty (20) days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time, a JUDGMENT OR NON PROS WILL BE ENTERED AGAINST YOU. VI ti<fi'1 SN (3) The date of service - of this rule,Vf Is t l I date of mailing. Date: , 20 f r i kk Signature of Prothonotary or Deputy rt _�r I • R COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTY OF CUMBERLAND Case Mag. Dist. No: MDJ- 09 -3 -02 Ability Recovery Services LLC MDJ Name: Honorable Vivian Cohick V Address: 55 Penn Drive Fallen Goho Newville, PA 17241 Telephone: 717-776-3187 James T Mulligan Jr., Esq. Docket No: MJ- 09302 -CV- 0000189 -2013 PO Box 4031 Case Filed: 8/19/2013 Wyoming, PA 18644 Disposition Details Disposition Summary (cc -Cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ- 09302 -CV- 0000189 -2013 Ability Recovery Services LLC Fallen Goho Dismissed Without Prejudice 11/04/2013 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. . 4 Date Magisterial District Judge Vivian Cohick<t certify that this is a true and correct copy of the record of the proceedings containing the judgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 11/04/2013 2:06:11 PM Ability Recovery Services LLC Docket No.: MJ- 09302 -CV- 0000189 -2013 V. Fallen Goho Participant List Plaintiff(s) Ability Recovery Services LLC PO Box 4031 Wyoming, PA 18644 Defendant(s) Fallen Goho 307 Oakville Rd Shippensburg, PA 17257 Complainant's Attorney(s) James T Mulligan Jr., Esq. PO Box 4031 Wyoming, PA 18644 MDJS 315 Page 2 of 2 Printed: 11/04/2013 2:06:11 PM ]ii U.S. Postal Service. U.S. Postal Service,,, CERTIFIED MAILT, RECEIPT CERTIFIED MAIL, RECEIPT 1 in (Domestic Mail Only;No Insurance Coverage Provided) co (Domestic Mail Only;No Insurance Coverage Provided) i E co ii .j- For delivery information visit our website at www.usps.com,, = For delivery information visit our website at www.usps.com Q' Q, I p., OFFICIAL USE a i c0 Postage $m m Postage $ Certified Fee Cert ified Fee r9 Postmark 0 Po 0 Return Receipt Fee Here p Return Receipt Fee Here (Endorsement Required) (Endorsement Required) 9 CD Restricted Delivery Fee C3 Restricted Delivery Fee 9 . (Endorsement Required) O (Endorsement Required) a O Fe e3 P Total Postage&Fees $ �xx Man�! , •---- ,„ M m Sent Sent To ra ���i rq "gfreet," "t:No.; r n,, Street, No.; / I 4 CD or PO No. C -- '7--n-- O or P;Box No.�Q 7 (� y ' ,/ F at, City,Sta, ZI; ,4 / 72 r / C aS•te,ZIP+4 / ✓.�1:./�C X l ��i: J ice.'% PS Form 3800,August 2006 See Reverse for Instructions PS Form 3800,August 2006 See Reverse for Instructions PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN(10)DAYS AFTER filing the notice of appeal. Check applicable boxes) COMMONWEALTH �� ��PEEN�NSY ANIA COUNTY OF G(.t'%1L_� /X444- ;ss AFFIDAVIT: I hereby swear or affirm that I served do:3 , � 5,��jacV- copy of the Notii of/Appeal, Common Plea upon the Dristrict Justice designated therein on date of service) // /!O// 20 by p nal ervice &t...---thy(certified)(registered)mail,sender's receipt a ach hereto, rid upon appellee,(name), on / // / //-3 20 ❑ by personal service y (certified) (registered) mail, sender's receipt attached hereto. ❑ and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to whom the Rule was addressed on ,20 , II by personal service ❑ by(certified)(registered) mail,sender's receipt attached hereto. • SWORN FIRMED)AND SU:SCRIB ' BEFORE ME / THIS DAY OF r.'of i' ,20, „„t_ /✓�, / •i. atureofaffiant I Signature of offs s efore whr.!avit made - 141 iii4..a._/ Title of official frl 20/7 t � My commission expires on �� 20 `_. c �'.) ,.rT1 _ -<T' N _ CONNONINSAi TN Or PENNSYLVANIA <O —0 -- NOTARIAL SEAL _ v MARIE 3.IANTILLir NOTARY PUBLIC .. rYTv OF SCRANTON,LACKAWANNA COON '' _ v CONNI/lO�jJ PJR >ti MAY 21.2017 i' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 COMPLAINT IN CIVIL ACTION VS. DOCKET NO.: 13-6745-CV DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 FILED ON BEHALF OF PLAINTIFF ATTORNEY OF RECORD OF THIS PARTY: James T. Mulligan, Jr.,Esq. PA I.D # 51794 �w a.QD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 NO.: 13-6745-CV VS. DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or obligations to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator Courthouse Carlisle, PA 17013 717-240-6200 ABILITY RECOVERY SERVICES, LLC IN THE COURT OF COMMON PLEAS P.O. BOX 4031 OF CUMBERLAND COUNTY WYOMING, PA 18644 PLAINTIFF CIVIL DIVISION vs. FALLEN GOHO 307 OAKVILLE ROAD WYOMING, PA 17257 DOCKET NO. : 13-6745-CV DEFENDANT COMPLAINT NOW COMES, the Plaintiff by and through its Attorney, James T. Mulligan, Jr., Esquire and hereby complains as follows: 1. The Plaintiff is ABILITY RECOVERY SERVICES, LLC, a Pennsylvania Limited Liability Company with a mailing address located at P.O. Box 4031, Wyoming, Luzerne County, Pennsylvania and offices located at 1 Montage Mountain Road, Moosic, Lackawanna County, Pennsylvania. 2. The Defendant is Fallen Goho, adult individual, who currently resides at 307 Oakville Road, Wyoming, Cumberland County, Pennsylvania, 17257. COUNTI - CONTRACT 3. Defendant applied for and received a consumer loan with CitiFinancial Plus, bearing the account number(2009180307384), on or about November 17, 2009. 4. Defendant's unpaid principal balance is Three Thousand One Hundred Eighty Two Dollars and Sixty One Cents ($7,586.34) (unpaid principal balance) as of November 20, 2013, plus interest and fees. See statement attached as Exhibit"A". 5. Defendant is in default of aforesaid Agreement, as of August 30, 2010, the date of her last payment, by failing to make required monthly payments when due. As such,the entire balance is immediately due and payable to Plaintiff, pursuant to said agreement. 6. Plaintiff purchased the Defendant's debt on August 10, 2012. See Plaintiff's Bill of Sale and Chain of title, collectively attached as Exhibit`B". 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff,thus damaging Plaintiff. Wherefore,the Plaintiff, ABILITY RECOVERY SERVICES, LLC,prays for judgment in its favor and against Defendant, Fallen Goho, individually, in the amount of$12,000.00 (unpaid principal balance plus interest and fees up to date of judgment),plus subsequent 6% interest on the judgment obtained. Dated: l � ames T. Mulligan, Jr., Esquire A I.D # 51794 P.O. Box 4031 Wyoming, PA 18644 (866) 760-6205 ext. 235 In-House Counsel for Plaintiff This company is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities,that he is JAMES T. MULLIGAN,JR., IN- HOUSE COUNSEL, authorized agent of ABILITY RECOVERY SERVICES, LLC, Plaintiff herein that he is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint, are true and correct to the best of his knowledge, information and belief. Date: 11 21 3 J es 1. Mulligan,.Jr., In Ho se Counsel 1 4 Exhibit „A„ Exhibit „ B „ Contract ID:UN2NU 1 MB031212 Document ID: 030812UN2NU 1 MBB 1 EXHIBIT 2 BILL OF SALE THIS BILL OF SALE is dated as of March 13, 2012 between the undersigned entities, with offices located at 300 Saint Paul Place, Baltimore, MD 21202 (collectively, the "Seller") and Pilot Receivables Management, LLC , organized under the laws of the state of Ohio located at 10625 Techwoods Circle, Cincinnati, OH 45242. ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated March 12, 2012, between Buyer and the Seller (the "Agreement"), the Seller does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, all of the Seller's right, title and interest in and to the Accounts described in Section 1.2 of the Agreement. Except as provided for in the Agreement, this Bill of Sale is executed without recourse and without representations or warranties including, without limitation, warranties as to collectability. CitiFinancial, Inc. (Maryland); CitiFinancial Corporation, LLC (Delaware); CitiFinancial Delaware LLC(Delaware); CitiFinancial Services, Inc. (California); CitiFinancial Corporation (Colorado); CitiFinancial Services, Inc. (Delaware); CitiFinancial Services, Inc. (Georgia); CitiFinancial Inc. (Hawaii); CitiFinancial Services, Inc. (Ohio); CitiFinancial, Inc. (Iowa); CitiFinancial, Inc. (Kentucky); CitiFinancial Services, Inc. (Massachusetts); CitiFinancial Services, Inc. (Minnesota); CitiFinancial Services, Inc. (Missouri); CitiFinancial, Inc. (New York); CitiFinancial Company(Delaware); CitiFinancial, Inc.NC (North Carolina); CitiFinancial, Inc. (Ohio); CitiFinancial Services, Inc. (Oklahoma); CitiFinancial Services, Inc. (Pennsylvania); CitiFinancial, Inc. (South Carolina); CitiFinancial, Inc. (Tennessee); CitiFinancial, Inc. (Texas); CitiFinancial Services, Inc. (Virginia); CitiFinancial, Inc. (West Virginia); CitiFinancial Services, Inc. (Kentucky); CitiFinancial Services of Puerto Rico, Inc. (Puerto Rico) Seller — -77C-d 7o-4tl- By: (Signature) Name: �ICr{{�[�Z uu'it Micha®I Taulbe®,SVP GEID: 1000624635 Citibank,N.R. 7930 NW 110th St. S p Kane City,MO 64153 Title: 1 816-505-6864 michael.taulbee @citi.com CFNA Purchase and Sale Agreement.doc 1 3 s EXHIBIT B PILOT RECEIVABLES MANAGEMENT,LLC BILL OF SALE PILOT RECEIVABLES MANAGEMENT, LLC, for value received and in accordance with the terms of the Receivables Purchase Agreement by and between PILOT RECEIVABLES MANAGEMENT, LLC and ABILITY RECOVERY SERVICES LLC ("Purchaser"), dated as of August 10, 2012 (the "Agreement'), does hereby sell, assign, and transfer to Purchaser all of its good and marketable title, free and clean of all liens, claims and encumbrances in and to the Receivables listed in the Closing Statement attached as Exhibit A to the Agreement, without recourse and without representation or warranty of collectability, or otherwise, except to the extent stated in the Agreement. Executed on August 10,2012. MUG LFAS MANAGEMENT,LLC By KI Kristin E.D ughe Vice President of Jales rketing ver 012012 For Unifund Use ONLY 1 UNIFUND CCR,LLC CONFIDENTIAL Client# PID CID# State of Ohio ) County of Hamilton) ss. AFFIDAVIT Michelle Flege being sworn, deposes and says that she is an authorized representative of PILOT RECEIVABLES MANAGEMENT, LLC herein called assignor, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that the statements and representations herein are within her personal knowledge. There is due and payable from FALLEN F GOHO, Acct. 2009180307384, SSN : xxx-xx-4610, as of 04/29/2011, the amount of$7,586.34. The creditor for this account was CITIFINANCIAL SERVICES, INC.. The account was assigned, transferred and set over unto ABILITY RECOVERY SERVICES LLC on 08/10/2012. The undersigned acknowledges that in making this assignment, the assignor has made a complete assignment of said debt and that ABILITY RECOVERY SERVICES LLC is now the owner thereof, and they have complete authority tc settle, adjust, compromise and satisfy the same and that the assignor has no further interest in said debt for any purpose. DATED this day of 1 PILOT RECEIVABLES MANAGEMENT, LLC By: Michelle Flee Authorized Representative Title 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this by LLC. M_ ichelle Flege,Authorized Representative of MfOT RECEIVABLES MANAGEMENT, A ��At/Sr��j'*� My commission expires: MICHELLE R. KELLY NOTARY PUBLIC =STATE OF OHIO _ , Comm. Expires - � July 16, 2017 iSGaJ'i; N �\� of;0�\\��� Client#1935 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 _ WYOMING, PA 18644 NO: 13-6745-CV ' VS. = DEFENDANT _MC) FALLEN GOHO y 1e-'•' �'`` 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 CERTIFICATE OF SERVICE I, James T. Mulligan, Jr., Counsel for Plaintiff, hereby certifies that I have served a true and correct copy of the foregoing Complaint, by U.S. First Class Mail, postage prepaid,this date shown below, to the following: Fallen Goho 307 Oakville Road Shippensburg, PA 17257 Date: 11 Z� i3 J s T. Mulligan, Jr.,Wsq. Pp. Box 4031 Wyoming, PA 18644 PA ID 51794 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF -;-' ABILITY RECOVERY SERVICES, LLC s0 • P.O. BOX 4031 , c r ; WYOMING, PA 18644 o -r=, AMENDED COMPLAINT IN CIVIL ACTION VS. DOCKET NO.: 13-6745-CV DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 FILED ON BEHALF OF PLAINTIFF ATTORNEY OF RECORD OF THIS PARTY: James T. Mulligan, Jr., Esq. PA I.D # 51794 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 NO.: 13-6745-CV vs. DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 AMENDED COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or obligations to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Court Administrator Courthouse Carlisle, PA 17013 717-240-6200 ABILITY RECOVERY SERVICES, LLC IN THE COURT OF COMMON PLEAS P.O. BOX 4031 OF CUMBERLAND COUNTY WYOMING, PA 18644 PLAINTIFF CIVIL DIVISION vs. FALLEN GOHO 307 OAKVILLE ROAD WYOMING, PA 17257 DOCKET NO. : 13-6745-CV DEFENDANT AMENDED COMPLAINT NOW COMES, the Plaintiff by and through its Attorney, James T. Mulligan, Jr., Esquire and hereby complains as follows: 1. The Plaintiff is ABILITY RECOVERY SERVICES, LLC, a Pennsylvania Limited Liability Company with a mailing address located at P.O. Box 4031, Wyoming, Luzerne County, Pennsylvania and offices located at 1 Montage Mountain Road, Moosic, Lackawanna County, Pennsylvania. 2. The Defendant is Fallen Goho, adult individual, who currently resides at 307 Oakville Road, Wyoming, Cumberland County, Pennsylvania, 17257. COUNT I - CONTRACT 3. Defendant applied for and received a consumer loan with CitiFinancial Plus, bearing the account number(2009180307384), on or about November 17, 2009. 4. Defendant's unpaid principal balance is Three Thousand One Hundred Eighty Two Dollars and Sixty One Cents ($7,586.34) (unpaid principal balance) as of November 20, 2013, plus interest and fees. See statement attached as Exhibit "A". 5. Defendant is in default of aforesaid Agreement, as of August 30, 2010, the date of her last payment, by failing to make required monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff, pursuant to said agreement. 6. Plaintiff purchased the Defendant's debt on August 10, 2012. See Plaintiff's Bill of Sale and Chain of title, collectively attached as Exhibit"B". 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff, thus damaging Plaintiff Wherefore, the Plaintiff, ABILITY RECOVERY SERVICES, LLC, prays for judgment in its favor and against Defendant, Fallen Goho, individually, in the amount of$12,000.00 (unpaid principal balance plus interest and fees up to date of judgment), plus subsequent 6% interest on the judgment obtained. Dated: til 1'4 oa TWA a es T. Mulligan, Jr., ri,uire P;' I.D # 51794 :.0. Box 4031 Wyoming, PA 18644 (866) 760-6205 ext. 235 In-House Counsel for Plaintiff This company is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. Section 4904 relating to unsworn falsification to authorities, that he is MAUREEN NAPOLETANO, authorized agent of ABILITY RECOVERY SERVICES, LLC, Plaintiff herein that he is duly authorized to make this verification, and that the facts set forth in the foregoing amended Complaint, are true and correct to the best of his knowledge, information and belief. )(.;'Date: / 17// - Ma een Napole Paralegal Exhibit O o 00000000000000000000000000000000000M-13P-3-h fia C)r+7 CU c).I--to o-o O m o W 0000 N)N N)N N N N N)N)N)CO(.J W G)C.)CO CO C.)CO CO a a A C W CD 7 Di H.P•03 0 CD(D73 CD Cv 7 0 7 F'0 -IN ni CO VCO CD0-'NWACTW VOD0001NW 4,(TCDVCO(001NW 4,01 0)VCO000-+NMZH•HCn 7 Z<< 7'7 CO 7 Co Di 0 7 CD Di C)-h7 7 CD H.co m 3 r•3 0 H 0.-0<(n o ••0 V)M(n (nm-I-1MM W-7-i-iMMo-1-i C7-i H.-3---F'rt(D 7 0 CD O C o (n c O W 2z-v z m 37=77.7ZZZZ-0773170 zz03737 zz z zzzzzzz zz zz Z07] CD P) 7 N CD -3 o 0'7 N 7 CD-♦ D-iD-A-A D mOH-i-♦-i-iD mOH-♦-{-10H-•1-A-A-A-♦-i-i-i-i-i-i-i-i-A-Aoz-n(n co77-O r+O (a 0HD)0 r• CD r-+H.3 3 r• C C)CD r+C) 3k N -i C)-H(7o--iD-1-1C)00)07-1D-1-iC7(7o-1-100000))CC)COC)C) 7C7o-i(D r+r+0_ r 0 O H.0 It J o)c3CCC3)r377)C C CC7or0-0-000-0-0-c C C C C C C C C C C C C C C m 7- 7'0 C0 CD 0 0 0 C CO D(n D(n(n D r D D W(n(n(n D r D D W(n D D D Cn fn W(n W W W(n(n(n(n(n(n(n(n(n D 7 CD 7 a C2 co m (7_ co 0 7 7 V z o z 00Z0ZZ00000-0ZZOOWZZ000000000000000 C)Z CD H.CD CC •• (D •• > EZ EZ MZ oE(n CO EZ EZ EZ EZ `2(n(n M M 0 OD 0)EC M ME=MEC EC EC?M EC EC MEC M 37 W-h CD 3 CD(D 02 CD 7 C) 0 mC7mmC7Dmmmrn rn TC)Dmmmmmm-nmmmmmmmmmmmmmIll TH• C H- CU CU 0 CO 07007-7-o W mm7-703-W O W TT7370 mm707(7 7-70 37 70 7-37 77 77 77 77 37 7-70-0 7 C O.C•< r+ Q. 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W ss CO 007 W N 0 O O 0002-i 0x OOOOOC:TIm - N W A(nom Zmm H O IC)x -0zZZm0:0m-1 C)-1--I-1 D0Z 7L 1-000-10-1 V D(cn(cnco>0)DO)� Z000ZC)ZVD 7301 . -om mmOH• NO) 70707.1700-0 0 V 0 0-Im • N 0707373mN0OO mmmm 0x(00 m C)C)C)Z Z�-(0 0 0 0 0 0 D W--� CO 70 70 x--1 -1 CO 0 0 0 0 0 H W mDDDz 0 (7HHH-1 W TzzzD o0 -I-I-400 A r m D C) C) 0 C zD -Ix n V- V CO CO Wm >>:0O 0000 VD 0000 WO 0 0 0 0 Z CO O OO(0 m 0(n • o C Z 0 Dm -1 m m x mm H (n 0 0 x D CO 0 73 x (D 0 x m _ cD Z Z O Cfl -1(/) DZ 0 CO 0 H 0 C v x -Dx -1 r o m m x H Z D-1 D 0 m m oxmc C m Z 1- 1 >0 D 0 1 0 17 moO Dm A m m— O�D Coro Zxr- -10m1 Z m W DD r- 0> cz zO �m D n N(7 Z H >z 01 > 0 m 0 ▪D zm m 0 0 NN-+-+ 0 0 W Exhibit „ B „ • Contract ID:UN2NUIMB031212 Document ID:030812UN2NU I MBB 1 EXHIBIT 2 BILL OF SALE THIS BILL OF SALE is dated as of March 13, 2012 between the undersigned entities, with offices located at 300 Saint Paul Place, Baltimore, MD 21202 (collectively, the "Seller") and Pilot Receivables Management, LLC , organized under the laws of the state of Ohio located at _ 10625 Techwoods Circle, Cincinnati, OH 45242. ("Buyer"). For value received and subject to the terms and conditions of the Purchase and Sale Agreement dated March 12, 2012, between Buyer and the Seller (the "Agreement"), the Seller does hereby transfer, sell, assign, convey, grant, bargain, set over and deliver to Buyer, and to Buyer's successors and assigns, all of the Seller's right, title and interest in and to the Accounts described in Section 1.2 of the Agreement. Except as provided for in the Agreement, this Bill of Sale is executed without recourse and without representations or warranties including, without limitation, warranties as to collectability. CitiFinancial, Inc. (Maryland); CitiFinancial Corporation, LLC(Delaware); CitiFinancial Delaware LLC(Delaware); CitiFinancial Services, Inc. (California); CitiFinancial Corporation (Colorado); CitiFinancial Services, Inc. (Delaware); CitiFinancial Services,Inc. (Georgia); CitiFinancial Inc. (Hawaii); CitiFinancial Services, Inc. (Ohio); CitiFinancial, Inc. (Iowa); CitiFinancial, Inc. (Kentucky); CitiFinancial Services, Inc. (Massachusetts); CitiFinancial Services, Inc. (Minnesota); CitiFinancial Services, Inc. (Missouri); CitiFinancial,Inc. (New York); CitiFinancial Company(Delaware); CitiFinancial, Inc.NC (North Carolina); CitiFinancial, Inc. (Ohio); CitiFinancial Services,Inc. (Oklahoma); CitiFinancial Services, Inc. (Pennsylvania); CitiFinancial, Inc. (South Carolina); CitiFinancial, Inc. (Tennessee); CitiFinancial,Inc. (Texas); CitiFinancial Services, Inc. (Virginia); CitiFinancial, Inc. (West Virginia); CitiFinancial Services, Inc. (Kentucky); CitiFinancial Services of Puerto Rico, Inc. (Puerto Rico) Seller (Signature) Name: i wound Taulbee,VP 1 }(Z (ALtL3 GELD: 1000624635 Citibank.NA. 7930 NW 110th St. S i n Kansas City,MO 64153 Title: 816-505-6884 michael.taulbee @citi.com CFNA Purchase and Sale Agreement.doc 1 Y Fund EXHIBIT B PILOT RECEIVABLES MANAGEMENT,LLC BILL OF SALE PILOT RECEIVABLES MANAGEMENT, LLC, for value received and in accordance with the terms of the Receivables Purchase Agreement by and between PILOT RECEIVABLES MANAGEMENT, LLC and ABILITY RECOVERY SERVICES LLC("Purchaser"), dated as of August 10, 2012 (the "Agreement"), does hereby sell, assign, and transfer to Purchaser all of its good and marketable title, free and clean of all liens, claims and encumbrances in and to the Receivables listed in the Closing Statement attached as Exhibit A to the Agreement, without recourse and without representation or warranty of collectability, or otherwise, except to the extent stated in the Agreement. Executed on August 10,2012. PIL d T - : :L' MANAGEMENT,LLC By Kris n E.D+ughe Vice President of'. - :rketing ver 012012 For Unifund Use ONLY I UNIFUND CCR,LLC CONFIDENTIAL Client# PID CID# State of Ohio ) County of Hamilton) ss• AFFIDAVIT Michelle Flege being sworn, deposes and says that she is an authorized representative of PILOT RECEIVABLES MANAGEMENT, LLC herein called assignor, which is doing business at 10625 Techwoods Circle, Cincinnati, Ohio 45242 and that the statements and representations herein are within her personal knowledge. There is due and payable from FALLEN F GOHO, Acct. 2009180307384, SSN : xxx-xx-4610, as of 04/29/2011, the amount of$7,586.34. The creditor for this account was CITIFINANCIAL SERVICES, INC.. The account was assigned,transferred and set over unto ABILITY RECOVERY SERVICES LLC on 08/10/2012, The undersigned acknowledges that in making this assignment,the assignor has made a complete assignment of said debt and that ABILITY RECOVERY SERVICES LLC is now the owner thereof, and they have complete authority tc settle, adjust, compromise and satisfy the same and that the assignor has no further interest in said debt for any purpose. r DATED this - I day of f 0 V e env";h ; d /3 hi ` C :, & PILOT RECEIVABLES MAN/,A GEMENT, LLC By: Michelle Flege Authorized Representative Title 10625 Techwoods Circle Cincinnati, OH 45242 Address Subscribed and sworn to before me this 1 LA 3 by Michelle Flege,Authorized Representative of OT RECEIVABLES MANAGEMENT, LLC. \�,0,4l isiiln;,,,, My commission expires: ���, \\\\\0�p,R... 15‘.4c:1 I,,, ` ?��\ � ., MICHELLE R. KELLY j) ' I li r t, / ' = NOTARY PUBLIC V J ® � _ -STATE OF OHIO , .y Y • :.. , :Y-, .--.• ' Comm. Expires �1 .,...k:.4.,,, ,,,,...> :4''fi. . : July 16, C) Client#1935 j..`L. r. t"_ r' t;E.! 1 110n �! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2014 JAN 23 PH i_ 35 PLAINTIFF CUMBERLAND COUTv ABILITY RECOVERY SERVICES, LLC PENNSYLVANIA' P.O. BOX 4031 WYOMING, PA 18644 NO: 13-6745-CV vs. DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 CERTIFICATE OF SERVICE I, James T. Mulligan, Jr., Counsel for Plaintiff, hereby certifies that I have served a true and correct copy of the foregoing Amended Complaint via First Class Mail, postage prepaid, this date shown below,to the following: Fallen Goho 307 Oakville Road Shippensburg, PA 17257 Date: i/2-/ V At day. /111 Ja�*esyT. Mulligan, J ., sq. P.O. Box 4031 Wyoming, PA 18644 - PA ID 51794 Counsel for Plaintiff IN THE COURT OF COMMON PLEAS OF '�� r�` CUMBERLAND COUNTY,PENNSYLVANIA s? ANN: CIVIL DIVISION ':Iifri3ERLAND CCUNf' PLAINTIFF PENNSYLVANIA ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 . WYOMING, PA 18644 • : NO.: 13-6745-CV vs. • • DEFENDANT • FALLEN GOHO : 307 OAKVILLE ROAD • SHIPPENSBURG, PA 17257 .• PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter and index the judgment for Ability Recovery Services, LLC against Fallen Goho the amount of$12,000.00, plus legal interest from February 26, 2014. Default Notice pursuant to PA. R.C.P. 237.1(A)(2) and proof of service of same is attached, and more than ten (10) days has elapsed since service of same. Notice of Judgment to be given to all parties pursuant to PA. R.C.P. 236. Dated d I )4 Signature: ?A f' I 11 '' A ames T. Mulligan,'Jr., Esq. Address: '.O. Box 4031 Wyoming, PA 18644 Attorney for: Plaintiff Telephone: 866-760-6205 ext. 235 Supreme Court ID: 51794 �" JUDGMENT Now,this I 0 day of 1��wY; 2014,judgment for Ability Recovery Services, LLC, against Fallen Goho, in the amount of$12,000.00, plus legal interest from today's date is hereby entered and indexed in the judgment index. Notice of judgment to all parties is her y gi urgErpi to Pa. R.C.P. 236. ,.,a i Protho o ary , 6 °' By: Deputy d, � �1u. o Pa ti NY,tce t Acii-teA S(3 -7 6 o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA PLAINTIFF ABILITY RECOVERY SERVICES,LLC P.O.BOX 4031 WYOMING, PA 18644 NO.: 13-6745-CV vs. COMPLAINT IN CIVIL ACTION DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG,PA 17257 To: FALLEN GOHO,DEFENDANT Date of Notice: February 12,2014 IMPORTANT NOTICE PURSUANT TO PA.R.C.P.NO.237.1(Ax2)YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN(10)TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COURT ADMINISTRATOR,4TH FLOOR COURTHOUSE CARLISLE,PA 17013 717-240-6200 Signature: tt,,.,,'' )1\/4'jit(Ir ES T. MULLIGAN,JR., •dress: P.O. Box 4031 Wyoming, PA 18644 Attorney for: Plaintiff Telephone: 855-207-3383 ext. 235 Supreme Court ID: 51794 9315 2?11 /0o9 2'253 a°2 U.S. Postal Service,. CERTIFIED MAILTM RECEIPT (Domestic Mail Only;No Insurance Coverage Provided) f` For delivery information visit Our website at www.usps.come fU r-1 m Postage $ Certified Fee ru Return Receipt Fee Postmark Q (Endorsement Required) Ffere 3. Restricted Delivery Fee (Endorsement Required) O t fU Total P•.- e&Fees $ 7" Air -nt To / / Street,or PO B./No.: r! .r. 5:4:...��� ............ r_ .. City S de 1P+f 4 /7b),1— PS Form 3800,August2006 See Reverse.for Instructions • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 Plaintiff(s) File No.: 13-6745-CV vs. FALLEN GOHO • 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 Defendant(s) AFFIDAVIT OF NON-MILITARY SERVICE I, James T. Mulligan, Jr., Esq., In-House Counsel for Plaintiff, state that to the best of my knowledge, information and belief,that the Defendant, Fallen Goho, 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. Dated: /4 \i t4 RESPECTFULLY SUBMITTED, J- ' S T. MULLIGAN, JR.A Q. ATTY ID#:Ir794 In House Counsel for Plaintiff PO Box 4031, Wyoming, PA 18644 (570) 207-1892 Ext 235 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 NO.: 13-6745-CV • vs. : • DEFENDANT : • FALLEN GOHO : 307 OAKVILLE ROAD : SHIPPENSBURG, PA 17257 : Pa. R.C.P. 236 NOTICE Notice of Judgment to be given to all parties pursuant to PA R.C.P. 236. Respectfully Submitted, Date: W \ ` r i J. : T. Mulligan, Jr., Esq. 5' • Box 4031 ■ oming, PA 18644 PA ID # 51794 In House Counsel for Plaintiff 4git.11 . ves)1116 fr.,,,,., — 0711)*1 11*''' •yam 00 1 cf, 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.: 13-6745-CV VS. FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 Defendant E.D. PRAECIPE FOR WRIT OF EXECUTION (LEVY — PERSONAL PROPERTY) TO THE PROTHONOTARY: Issue writ of execution on the above matter, directed to the Sheriff of Cumberland County 7 (1) You are directed to levy upon the property of the Defendant and sell his interest therein, against Fallen Goho, Defendant; and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Fallen Goho; (a) and enter this writ in judgment index against Fallen Goho, Defendant JUDGMENT: $12,000.00 INTEREST: $68.95 PROTHONOTARY: $ SHERIFF: $ TOTAL RESPECTFULLY SUBMITED, s T. Mulligan, Jr., Es Box 4031 yoming, PA 18644 PA ID # 51794 (866) 760-6205 ext. 235 c2F.it (3 In-House Counsel for Plaintiff 1 65 60 C-S- I 14. g• c-c-- CLAtotpCoc z:sL-1(wi Lc br s6 1-s„ 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. FALLEN GOHO WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13 -6745 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against FALLEN GOHO, 307 OAKVILLE ROAD, SHIPPENSBURG, PA 17257 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; LEVY UPON AND SELL ALL OTHER REAL AND PERSONAL PROPERTY BELONGING TO THE DEFENDANT. (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of GARNISHEE(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 $12,000.00 Plaintiff Paid Interest $68.95 Law Library $.50 Attorney's Comm. % Due Prothonotary $2.25 Other Costs Attorney Paid $148.50 Date: 4/8/14 --E44.ze".c.L'I 1,0A 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 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW I. $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 2 RONNY R. ANDERSON Sheriff JODY S. SMITH Chief Deputy To Whom It May Concern: ootv of Currrbeti OFFICE OF THE SHERIFF One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 RICHARD W. STEWART Solicitor C) ^o cxi zr-11 June 16, 2014 <� CD Ability Recovery Services vs Fallen Goho Writ No. 2013-6745 Property Claim Determination rn -H Reference is made to Property Claim received June 6, 2014, entered by Clarence E. Chestnut, II, Cumberland County Writ No. 13-6745, Ability Recovery Services vs Fallen Goho. Ronny R. Anderson, Sheriff, has determined that the claimant, Clarence E. Chestnut II, in the above mentioned property claim, is the owner of the property set forth in the claim. cc Clarence E. Chestnut II, Claimant Fallen Goho n/k/a Fallen Chestnut, Defendant James T. Mulligan, Jr., Attorney for Plaintiff R. Anderson, Sheriff NOTICE OF PROPERTY CLAIM Ability Recovery Services, LLC VS Fallen Goho In the Court of Common Pleas Cumberland County, Pennsylvania Writ of Execution No. 2013-6745 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 Clarence E. Chestnut II, 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 06-06-14 Cc of Cumberland County Clarence E. Chestnut II, Claimant Fallen Goho n/k/a Fallen Chestnut, Defendant James Mulligan, Attorney for Plaintiff l' PROPERTY CLAIM In the Court of Common Pleas of CZ 1e1 1s Ch es) -A0 -1 - TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA Cumberland County, Pennsylvania Writ No. 13- (0'7 4-(5 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 '.Zn 5601_ 13) Udo Oo D� UW ? e v\C-5 Q SERI4M— ora 13 to'S? -5otad M- N C sr\ SER -7-.L4; L 4VA(9(De\11 5e) nd g1 12.—Pc—C: AG. s s\me-: ✓ , . ,�, c10,0© C o M? I 4 p vl�tiz 6 o R- 1V\IP6TSR&LLQ 1-T • 300,00 loDibb Date b r S 1 t-{ State of Pennsylvania: County of Cumberland 1-044 above list in the property claim are correct and true. r Claimant being duly sworn according to law, deposes and says that the Sworn and subscrib - d to before me day . fly' i je Notary PA► i• 1.1 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEA!.. Ti MMiM`l SUE `SEL MAN, Notary Public Boro of Shippcnsourg, Cumberland County My Commission Expires February 10, 2018 Apr 18, 2013 Rent -A -Center 200 S Spring Garden St Carlisle PA 17013-2578 (717) 245-0330 LOC: 4585-M RENTAL -PURCHASE AGREEMENT Agreement Number: deh08445 Consumer: CHESTNUT, FALLEN 307 Oakville Rd Shippensburg PA 17257-9748 (717) 386-6022 RT: 02 MIS OFAGREEMENT, As used in this Agreement, 'you' and "your" mean the person(s) signing the Agreement as lessee/renter/consumer; "we" and •our° ,nean the lessor/owner (the rental company);"property- means the items described in the disclosures; and 'lease' means this Rental -Purchase Agreement including the disclosures. Pg.W P`I'TOlx1 OF Pf ._._,P _ Item # Item Description 0458503525 FURNITURE /LIVING ROOM G 0458503510 FURNITURE /FIREPLACE (EL RENTAL -PURCHASE DISCLOSURES Serial # S415801651 AN35331 M-1 Model # 7860138/23 80717 Condition of Property: NEW NEW :RENTAL TEF M Weekly Rental payments are due at the beginning of each term that you choose to rent the property. There are no refunds if you choose to return theproperty before the end of the term. INITIAL?AYMENT: Payments are due at the beginning of each term that you choose to lease the property. Your initial payment will include the followin charges: Rental Payment -Optional Liability Dampge Waiver Tax Total $.00 $.00 $.00 $.00 RENEVIfA5AYMS You are not obligated to renew this Agreement beyond the initial term. However, if you choose to renew this Agreement beyond the initial term, or beyond any subsequent renewal term, you may do so by making an advance rental payment on the Thursday of each Week , or you may choose to make advance rental payments on a Semi -Monthly or Monthly basis. Your first renewal payment is due Thursday Apr 18, 2013 Day Date Payments Rental Payment Optional Liability Damage Waiver Tax Total Weekly $41.99 $3.15 $2.71 $47.85 Semi -Monthly $90.90 $6.82 $5.86 $103.58 Monthly $181.94 $13.65 $11.74 $207.33 fiE}' At C S - If you choose to acquire ownership, you must rent the property for the number of weeks, semi -months or months shown below. The Total Cost does not include other charges or fees. You should read the contract for an explanation of these charges and fees. Weekly If you choose to acquire ownership through weekly rental, you will make 100 payments: the initial rental payment of $.00 , 98 weekly payments of $41:99 and a final payment of $41.99 for a total of $4,157.01 in rent and sales tax of $249.48 for a Total Cost of $4,406.49 . Semi-monthly If you choose to acquire ownership through semi-monthly rental, you will make 47 payments: the initial rental payment of $.00, 45 semi-monthly payments of $90.90 and a final payment of $54.54 for a total of $4,145.04 in rent and sales tax of $248.52 for a Total Cost of $4,393.56. If you choose to acquire ownership through monthly rental, you will make 24 payments: the initial rental payment of $.00 , 22 monthly payments of $181.94 and a final payment of $145.55 for a total of $4,148.23 in rent and sales tax of $248.97 for a Total Cost of $4,397.20 . If you choose to renew this Agreement on a frequency different f-om your initial rental payment term, your total amount will be calculated based on the above amounts and on the number of payments made at each frequency. Free rent allowance will not reduce total rent or purchase -option amounts. Sales taxes are subject to changes in the applicable tax rate. $2,720.05 , plus sales tax. 1,436.96 , plus sales tax. OT Optional Liability Damage Waiver Fee Late Fee $13.65 /Month The greater of $5.00 or 5% of the past due payment if 5 days $6.82 /Semi -Month or more late on a monthly agreement or 2 days or more late on a ,$3.15 /Week semi-monthly or weekly agreement. 1=ARLl�?C/SOpONYou have the option to purchase the rented property at any time by tendering an amount equal to the amount by which the cash price of the leased property exceeds 65 % of all rental payments made by the lessee. In addition, you may purchase the property within the first 90 days after the dateofthis agreementby paying us an amount equal to the Cash Price minus the total of all rental payments (excluding tax) made by you, plus t RENT REDUCTaQN' If you have paid more than two-thirds (2/3) of the Total of Payments required to acquire ownership and you experience a loss or interruption of income, you may qualify for a reduced rental payment. Please see the employees at our store for details. I ISI 04 _ - OM,You are liable for loss, damage in excess of normal wear and tear, or destruction of the rented property. You will be liable to us for the cost of re ap irs or the proms fair market, whichever is.less. Your liability will not exceed the amount of your Early Purchase Option. ftRTIC AL111iYMBI fAiVfAdk-W,=, lit: You are not required to purchase liability damage waiver for the property that is the subject of the rental agreement from us or from any vendor owned or controlled by us. TVOi=TRANBAC QN: THIS IS A RENTAL TRANSACTION_ R lNSTATE MEtJt` If you fail to make a timely rental payment, you may reinstate the agreement without losing any rights or options which exist under the agreement by the payment of all past due charges and any applicable late fee within 7 days of the renewal date. If you have paid less than 2/3 of the total payments necessary to acquire ownership and you have returned or voluntarily surrendered the property, other than through judicial process, during the applicable reinstatement period set forth above, you may reinstate the agreement during a period of not less than 90 days after the date of the retum of the property. If you have paid 2/3 or more of the total payments necessary to acquire ownership, that period shall be extended to 120 days. Upon reinstatement, we shall provide you with the same property or substitute property of comparable quality and condition. TERMINAl7 You may terminate the rental -purchase agreement without penalty by voluntarily surrendering or retuming the goods in good repair, reasonable wear and tear excepted, alona with anv oast rii IP rPnraI nn,imo»f ' " Monthly OFFICE OF THE SHERIFF COUNTY, PA ZUNI JUN -b P 2: 41 ?J3iclaD /() UCIN 0)4c. (_IA--16tgair_.th \a A-$) .v\x-iQG co' oe 001GQL 06c:0:2 Cr 0°1 Q vs)-rg-cs\ S"-INclk-NT) • c.soapa.9 (\c")34 sa---19a C 67573860 LIZLII net t COMMONWEALTH OF PENNSYLVANIA REGISTRATION CREDENTIAL EXPIRY: FEB 28, 2015 VALID: 03/04/14 PLATE: 3MB1727 TITLE: 72609640302 CH WID: 14063 3400 031153-001 VIN: KNDJT2A65C7358457 YR/MAKE: 2012 KIA TITLE BRANDS: EMISSION INSPECTION REQUIRED/DIESEL EXEMPT COUNTY : CUMBERLAND CLARENCE E CHESTNUT II FALLEN F CHESTNUT 307 OAKVILLE RD SHIPPENSBURG PA 17257 SIGNATURE I hereby acknowledge this day that I have received notice of the provisions of Section 3709 of the Vehicle Code Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SHERIFF THE PROTHONOTARY 2014 JUN 2 7 PH 2: 41+ CUMBERLAND COUNTY PENNSYLVANIA Ability Recovery Services, LLC vs. Fallen Goho Case Number 2013-6745 SHERIFF'S RETURN OF SERVICE 05/14/2014 07:16 PM - Jamie DiMartle, Deputy , being duly sworn according to law, states that on May 14, 2014 at 7:16 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: Fallen Goho at 307 Oakville Road, North Newton Township, Shippensburg, PA 17257, 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 May 15, 2014. INTERROGATORIES WERE ALSO SERVED UPON DEFENDANT. 06/06/2014 On June 06, 2014, at 1441 hours, a property claim was filed by Clarence E. Chestnut, II. All parties notified by mail this date. 06/16/2014 Reference is made to Property Claim received June 6, 2014, entered by Clarence E. Chestnut II, Writ of Execution No. 2013-6745, Ability Recovery Services vs Fallen Goho (n/k/a Fallen Chestnut). Ronny R Anderson, Sheriff, has determined that the claimant, Clarence E. Chestnut II, in the above mentioned property claim, is the owner of the property set forth in the claim. 06/27/2014 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: $120.11 SO ANSWERS, June 27, 2014 (c) CountySuite Sheriff, Teleosoft. Inc. a. ,Sit9dr 02. , Sa 1_-G,04)( 9 99y' 3 0729/ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION PLAINTIFF ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT FALLEN GOHO 307 OAKVILLE ROAD SHIPPENSBURG, PA 17257 NO.: 13 -6745 -CV - LP y z y' 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 23, 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, Jr., E # 51794 ouse Counsel for Plaintiff 570-207-1892 (ext. 235)