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Home My WebLink About13-7322 C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU kr N ,` ROTH'ONOTAW > COMMONWEALTH OF PENNSYLVANIA 2 013 DEC 12 PM 2: 4 3 CIVIL DIVISION CUMBERLAND COUNTY ABILITY RECOVERY SERVICES, LLC PENNSYLVANIA P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Docket No. J3---)3o?a v VS. NOTICE OF FILING ASHLEY HEWITT JUDGMENT 304 SHIPPENSBURG ROAD SHIPPENSBURG, PA 17257 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) _ -------------------------------- a. Date of Instrument: OCTOBER 24,2013 b. Amount: $ 5,828.92 2. Enter the judgment in favor of the original holder, or (unless expressly forbidden in the instrument) in favor of the assignee or other transferee; 3. I hereby certify that the residence of the plaintiff is: P. O. BOX 4031, WYOMING, PA 18644 I hereby certify that the residence of the Defendant is: 304 SHIPPENSBURG ROAD, SHIPPENSBURG, PA 17257 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. ORNEY FOR PiRINTIFF DATE: 041 3 NAME: James T. Mulligan, Esq. ATTORNEY ID NO: 51794 a Ak A ej g # aqc) N o h it r rya;1.4 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 ` tp Plaintiff Docket No. VS. ASHLEY HEWITT 304 SHIPPENSBURG ROAD SHIPPENSBURG, PA 17257 Defendant(s) AFFIDAVIT OF NON - MILITARY SERVICE I, James T. Mulligan, Esq., Attorney for Plaintiff, state that to the best of my knowledge, information and belief, that the Defendant, HEWITT, 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, _)Z )6 �. Dat d J s T. Mulligan, Esq. ATTY 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 U l ff � �� Plaintiff No. VS. NOTICE OF FILING JUDGMENT ASHLEY HEWITT 304 SHIPPENSBURG ROAD SHIPPENSBURG, PA 17257 Defendant (X) Notice is hereby given that a JUDGMENT in the above - captioned matter has been entered against you in the amount of $5,828.92 on OCTOBER 24, 2013 - (X) A copy of all documents filed with the Prothonotary/lerk, 1 t D' n in 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 COMMONWEALTH OF PENNSYLVANIA Notice of Judgment/Transcript Civil 'COUNTY OF CUMBERLAND - Case Mag. Dist. No: MDJ- 09 -3 -01 Ability Recovery Services LLC MDJ Name: ' Honorable H. Anthony Adams V Address: 35 West Orange Street Ashley Hewitt Shippensburg, PA 17257 Telephone: 717-532-7676 Ability Recovery Services LLC Docket No: MJ- 09301 -CV- 0000111 -2013 P. O. Box 4031 Case Filed: 8/27/2013 Wyoming, PA 18644 Disposition Summary (cc- Cross complaint) C Docket No Plaintiff Defendant Disposition O Disposition Date MJ- 09301 -CV- 0000111 -2013 Ability Recovery Services LLC Ashley Hewitt Default Judgment for Plaintiff 10/24/2013 Judgment Summary Participant Joint/Several Liability Individual Liability Amount Ability Recovery Services LLC $0.00 $0.00 _ $0.00 Ashley Hewitt $0.00 $5,828.92 $5,828.92 Judgment Finding ("Post Judgment) In the matter of Ability Recovery Services LLC vs. Ashley Hewitt on MJ- 09301 -CV- 0000111 -2013, on 10/24/2013 the judgment was awarded as follows: Judgment Component Joint/Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $5,633.97 $5,633.97 Filing Fees $0.00 $157.50 $157.50 Server Fees $0.00 $37.45 $37.45 Grand Total: $5,828.92 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. Date Magisterial District Judge H. Anthony Adams'` certify that this is a true and correct copy of the record of the proceedings containing the 1 dgment. Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 10/25/2013 7:59:39AM aS�a`r�a� ��oa Ability Recovery Services LLC Docket No.: MJ-09301 -CV-00001 11-2013 V. Ashley Hewitt y. j Participant List f Plaintiff(s) Ability Recovery Services LLC C°A P. O. Box 4031'�� -' Wyoming, PA 18644 r Defendant(s) Ashley Hewitt" 8464 Newburg Road Newburg, PA 17240 Complainant's Attorney(s) James T Mulligan Jr., Esq. PO Box 4031 Wyoming, PA 18644 MDJS 315 Page 2 of 2 Printed: 10/25/2013 7:59:39AM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Magisterial District Numbef: < PLAINTIFF: NAME and ADDRESS � MDJ Name: Hon. 09 -3 -01 (— ABILITY RECOVERY SERVICES,LLC HAROLD ANTHONY ADAMS P O BOX 4031 Address 35 WEST ORANGE STREET WYOMING, PA 18644 SHIPPENSBURG, PA 17257 PHONE NO: (855} 207 -1892 VS. Telephone: (717)532 -7676 DEFENDANT: NAME and ADDRESS F— ASHLEY HEWITT 304 SHIPPENSBURG ROAD SHIPPENSBURG, PA 17257 Docket No.: (,�� r► / �� Date Filed: AMOUNT DATE PAID FILING COSTS $ POSTAGE $ l l Social security numbers and financial information SERVICE COSTS $ l l (e.g. PINS) should not be listed. /f the identity of an CONSTABLE ED. $ l / account number must be established, list only the TOTAL $ 157.50 g l l/ last four digits. 204 Pa. Code §§ 213.1 - 213.7. 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 $ 5,633.97 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): ASHLEY HEWITT is indebted to CHASE BANK, USA bearing credit card account number XXXXXXXXXXXX1103 in the amount of $ 5,633.97 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES, LLC.,on DECEMBER 1, 2011 and last payment was made on SEPTEMBER 4, 2009. I 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. ignature of Plaintiff or Authori Agent) The plaintiffs attorney shall file an 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 . • WYOMING,PA 18644 . Plaintiff J.D.No.:13-7322-CV vs. . ASHLEY HEWITT E.D. 304 SHIPPENSBURG ROAD • SHIPPENSBURG,PA 17257 . P E ; wl .i Defendant • r, , _ MEMBERS FIRST FEDERAL CREDIT UNION — 1166 WALNUT BOTTOM ROAD = CARLISLE,PA 17015 . • Garnishee PRAECIPE FOR WRIT OF EXECUTION 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 Ashley Hewitt, Defendant;and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant, Ashley Hewitt; (3) and enter this writ in judgment index (a) against Ashley Hewitt,Defendant,and (b) against Members First Federal Credit Union,as garnishee,as a lis pendens against real property of the defendant in the name of garnishee as follows: n 9 0 o p _/ 1.)-t n/a o� Cl JUDGMENT:$5,828.92 31. 2 S INTEREST:$78.85 60 . 2. 5 pd PROTHONOTARY:$ SHERIFF: $ TOTAAL: RESPECTFULLY S,UBBMI,TEEDD,, '(.-- ----- Dated J es T.Mulligan,Jr.,Esq. .Box 4031 Wyoming,PA 18644 PAID#51794 (866)760-6205 ext.235 4%2. 2 S j/ ' CO, In-House Counsel for Plaintiff so it- c 5-5313 p#3oo6o,2 10(7L or e:r /5..S•vec/ 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.: 13-7322-CV • vs. ASHLEY HEWITT E.D. • 304 SHIPPENSBURG ROAD • SHIPPENSBURG, PA 17257 • Defendant • MEMBERS FIRST FEDERAL CREDIT UNION • 1166 WALNUT BOTTOM ROAD • CARLISLE, PA 17015 Garnishee WRIT OF EXECUTION NOTICE This paper is a Writ of Execution. It has been issued because there is a Judgment against you. It may cause your property to be held or taken to pay the Judgment. You may have legal rights to present your property from being taken.A lawyer can advise you more specifically of these rights. If you wish to exercise your rights,you must act promptly. The law provides that certain property cannot be taken. Such property is said to be exempt.There its a debtor's exemption of$300.00.There are other exemptions which may be applicable to you.Attached is a summary of some exemptions. You may have other exemptions or other rights. If you have exemption,you should do the following promptly(1) Fill out the attachment claim form and demand for a prompt hearing. (2)Deliver the form or mail it to the Sheriff's Office at the address noted. 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. Cumberland County Courthouse/4`h floor Court Administrator Carlisle, PA 17013 (717) 240-6200 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 13-7322 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 ASHLEY HEWITT-304 SHIPPENSBURG ROAD SHIPPENSBURG,PA 17257 (1) You are directed to levy upon the property of the defendant(s)and to sell LEVY UPON AND SELL OTHER REAL AND PERSONAL PROPERTY (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of MEMBERS FIRST FEDERAL CREDIT UNION GARNISHEE(S)as follows: MEMBERS FIRST FEDERAL CREDIT UNION- 1166 WALNUT BOTTOM ROAD CARLISLE,PA 17015 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$5,828.92 Plaintiff Paid$ Interest$78.85 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: 1/17/2014 1.11 L David D. Buell,Prothonotary • Deputy REQUESTING PARTY: Name : JAMES T. MULLIGAN,JR.,ESQ. Address: P.O. BOX 4031 WYOMING,PA 18644 Attorney for: Plaintiff Telephone: 866-760-6208 EXT 235 Supreme Court ID No. 51794 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson = $'HE PROI-fio Sheriff ) �,�xie�4,ai �rrtirta�,rrr�� L�(�1 Jody S Smith JAN 2.8 PM 2: 47 Chief Deputy Richard W Stewart „' CUMBERLAND COU�dTY Solicitor OrFC FTy $11I;1r PEtV�J51'LVAP�IA Ability Recovery Services, LLC Case Number vs. Ashley Hewitt 2013-7322 SHERIFF'S RETURN OF SERVICE 01/24/2014 02:09 PM - Shawn Gutshall, 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, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Meg Beaston, Customer Services Representative, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents ther of known to her. 2Q&;E- - ' A UTSHA EPUTY SO ANSWERS, January 27, 2014 RONNY R ANDERSON, SHERIFF (.C.)CountySune Sheriff,Teleosoft,inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c t` r Sheriff _ • 1HE P.:'`r10F ONU1p� Jody S Smith Chief Deputy Richard W Stewart Solicitor �nuati OFF10EOF TN: u5RI 2014 MAR 21 AM 9: 38 CUI1BERLAND COUNTY PENNSYLVANIA Ability Recovery Services, LLC vs. Ashley Hewitt Case Number 2013 -7322 SHERIFF'S RETURN OF SERVICE 01/24/2014 02:09 PM - Shawn Gutshall, 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, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, South Middleton Township, Carlisle, PA 17015, Cumberland County, by handing to Meg Beaston, Customer Services 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. 03/17/2014 06:58 PM - Deputies went to residence; spoke with current tenant who advised that they moved in last month and never heard of Ashley Hewitt. Put in for a Post Office check - USPS provided a new address of 8464 Newburg Road, Newburg, PA 17240 -9711. This address is located in Franklin County. 03/20/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ of execution is returned STAYED. Defendant moved from address provided to 8464 Newburg Road, Newburg, PA 17240 -9711, which is located in Franklin County. SHERIFF COST: $122.01 SO ANSWERS, March 20, 2014 tci CountySuite Sheriff, Teieoscti, RONZ ANDERSON, SHERIFF 0 0S` �� Co, pd' IN THE COURT OF COMMON PLEAS (77/ rr 1 j CUMBERLAND COUNTY PENNSYLVANIA, JO `'4p2;,� CIVIL DIVISION 010�` P 3. `++ PLAINTIFF ABILITY RECOVERY SERVICES, LLC : P.O. BOX 4031 WYOMING, PA 18644 DEFENDANT ASHLEY HEWITT 304 SHIPPENSBURG ROAD SHIPPENSBURG, PA 17257 NO.: 13 -7322 -CV NOTICE OF DEPOSITION IN AID OF EXECUTION Pursuant to Pennsylvania Rules of Civil Procedure 3117 and 4007.1, notice is hereby given that on September 25, 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: /10,11(fr Respectfully Submitted, "(ice-► 1 - es T. Mulligan, Jr., E d#51794 In -House Counsel for Plaintiff 570-207-1892 (ext. 235)