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Home My WebLink About14-0368 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. /4, 3 6 S VS. NOTICE OF FILING -v LISA BUFFINGTON JUDGMENT ` 1708 HUMMEL AVENUE, APT A a r- CAMP HILL, PA 17011 T Defendant PRAECIPE FOR ENTRY OF JUDGMENT TO THE PROTHONOTARY: 1. Enter judgment on the attached: ( ) Instrument confessing judgment or authorizing confession by an attorney at law or other person against the person who executed it. ( X ) Certified copy of judgment from a District Justice. () Other (please describe) --------------------------------- Date of Instrument: DECEMBER 6, 2013 b. Amount: $ 4,867.13 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: 1708 HUMMELAVENUE, CAMP HILL, PA 17011 4. Please give notice to the parties pursuant to Pa.R.C.P. 236. Qy�� T )f\A A RNEY FOR PLAINTIFF DATE: NAME: James T. Mulligan, Esq. �+ ATTORNEY ID NO: 51794 /ryj 5 33o 9.Z� 3 o d6a z COMMONWEAL TH OF PENNSYLVANIA Notice of Judgment/Transcript Civil COUNTYZ F CUMBERLAND _ Case � M Mag. Dist. No: MDJ- 09 -1 -01 Ability Recovery Services MDJ Name: Honorable Charles A. Clement Jr. V. Address: 920 Linda Lane Lisa Buffington Camp Hill, PA 17011 Telephone: 717 -737 -3434 Ability Recovery Services Docket No: MJ- 09101 -CV- 0000417 -2012 P. 0. Box 4031 Case Filed: 10/31/2012 Wyoming, PA 18644 Disposition Summary (cc -Cross complaint) Docket No Plaintiff Defendant Disposition Disposition Date MJ-091 01 -CV-0000417-2012 Ability Recovery Services Lisa Buffington Default Judgment for Plaintiff 12/06/2013 Judgment Summary Participant Joint /Several Liability Individual Liability Amount Ability Recovery Services $0.00 $0.00 $0.00 Lisa Buffington $0.00 $4,867.13 $4,867.13 Judgment Finding ( *Post Judgment) In the matter of Ability Recovery Services vs.. Lisa Buffington on MJ- 09101 -CV- 0000417 -2012, on 12/06%2013 the judgment was awarded as follows: Judament Component Joint /Several Liability Individual Liability Deposit Applied Amount Civil Judgment $0.00 $4,680.13 $4,680.13 Costs $0.00 $187.00 $187.00, . ,, Grand Total: $4,867.13' ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY /CLERK OF COURT OF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT /TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL. EXCEPT AS OTHERWISE. PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES, IF THE JUDGMENT HOLDER ELECTS TO ENTER THE iUDGrviENT ;N THE COURT OF COI:" o1ON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY . BE 1SSUEC}`$Y C E MAti:S F�l7l�ii i�tS i OIL 1'JUUts�. 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. EC - `62013 ,. ,fir; =. 40� Date Magisterial District Judge Charles A. Clement Jr.�;. certify that this is a true and correct copy of the record of the proceedings contain ng the l9dgmen t. ^ Date Magisterial District Judge MDJS 315 Page 1 of 2 Printed: 12/09/2013 1:02:58PM i • t Ability Recovery Services Docket No.: MJ- 09101 -CV- 0000417 -2012 r v. Lisa Buffington m Participant List Plaintiff(s) Ability Recovery Services P. 0. Box 4031 Wyoming, PA 18644 Defendant(s) Lisa Buffington 1708 Hummel Avenue Camp Hill, PA 17011 Complainant's Attorney(s) James T. Mulligan Jr., Esq. Ability Recovery Services LLC In House Counsel PO Box 4031 Wyoming, PA 18644 MDJS 315 Page 2 of 2 Printed: 12/09/2013 1:02:58PM COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CIVIL COMPLAINT Mag isterial District Number: 09-1 -01 f - PLA]IrT NAME and ADDRESS MDJ Name: Hon. ABILITY RECOVERY SERVICES, LLC CHARLES A. CLEMENT, JR. PO BOX 4031 Address: 920 LINDA LANE WYOMING, PA 18644 CAMP HILL, PA 17011 phone: (855) 207 -1892 VS. Telephone: (717)737 -3434 DEFENDANT: NAME and ADDRESS F_ LISA BUFFINGTON 1708 HUMMEL AVENUE ff�o T CAMP HILL, PA 17011 Docket No.: CV_0000417_12 Date Filed: 10/31/2012 AMOUNT DATE PAID FILING COSTS $ 143.00 11/14/12 POSTAGE $ 10.30 11 14/ 12 Social security numbers and financial information SERVICE COSTS $ l l (e.g. PINS) should not be listed. If the identity of an CONSTABLE ED. $ / / account number must be established, list only the TOTAL $ 153.50 1 14/ 12 last four digits. 204 Pa. Code §§ 213.1 - 213.7. Pa. R. C. P. D.J. No. 206 sets forth those costs recoverable by th p r e v a iling p TO THE DEFENDANT: The above named plaintiff(s) asks judgment against you for $ 4.680.13 together with costs upon the following claim (Civil fines must include citation of the statute or ordinance violated): LISA BUFFINGTON is indebted to CHASE BANK USA credit card bearing account number XXXXXXXXXXXX5649 in the amount of $4,680.13 to date. This outstanding debt was purchased by ABILITY RECOVERY SERVICES,LLC on DECEMBER 1, 2011 and the last payment was made on SEPTEMBER 14 2009. I, JAMES T. MULLIGAN, JR. verify that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. § 4904) related to unsworn falsification to authorities. (Signature of Plaintiff or Authorized Agent) The plaintiff's 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 COMMONWEALTH OF PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff Docket No. J 3 VS. LISA BUFFINGTON - a 1708 HUMMEL AVENUE, APT A CAMP HILL, PA 17011 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, BUFFINGTON, 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, Date J e T. Mulligan, EA. T 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 • - �d,z Plaintiff Docket N -365 VS. NOTICE OF FILING JUDGMENT LISA BUFFINGTON 1708 HUMMEL AVENUE, APT A CAMP HILL, PA 17011 Defendant (X) Notice is hereby given that a JUDGMENT in the above - captioned matter has been entered against you in the amount of $4,867.13 on Dr"�" (X) A copy of all documents filed with the Prothonotary*�lerk, 'vil on in suppo of the within judgment is /are enclosed. Proth y /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 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.:14-368-CV Vs. LISA BUFFINGTON E.D. 1708 HUMMEL AVENUE,APT.A CAMP HILL,PA 17011 Defendant MEMBERS FIRST CREDIT UNION 3:co � 1166 WALNUT BOTTOM ROAD r CARLISLE,PA 17015T CD Garnishee CD 'C: C�'7 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 Lisa Buffington, Defendant;and (2) You are further directed to levy upon and sell all other real and personal property belonging to the Defendant,Lisa Buffington; (3) and enter this writ in judgment index (a) against Lisa Buffington,Defendant,and (b) against Members First Credit Union,as garnishee,as a lis pendens against real property of the defendant in the name of garnishee as follows: n/a JUDGMENT:$4,867.13 INTEREST:$39.20 PROTHONOTARY: SHERIFF: $ TOTALL5 RESPECTFULLY SUBMITED, �s t raes �.Mulligan,Jr.,Esq. C� � x 4031 Wyoming,PA 18644 a� r)9, PAID#51794 (866)760-6205 ext.235 S a L In-House Counsel for Plaintiff lQ P ��. 2 � . sot.� 1' t'J4 ao o�S yr/ r'2D WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 14-368 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 LISA BUFFINGTON, 1708 HUMMEL AVENUE,APT.A,CAMP HILL,PA 17011 (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 (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: MEMBERS FIRST 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$4,867.13 Plaintiff Paid$ Interest$39.20 Attorney's Comm. % Law Library$.50 Attorney Paid$60.25 Due Prothonotary$2.25 Other Costs$ Date: 2/27114,. David D.Buell,Prothonotary r r- Deputy REQUESTING PARTY: Name:JAMES T.MULLIGAN,JR.,ESQ. Address: P.O.BOX 4031 WYOMING,PA 18644 Attorney for: PLAINTIFF Telephone: 866-760-6205 EXT.235 Supreme Court ID No. 51794 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ; Sheriff ClitiJber Jody S Smith Chief Deputy � 29 1 L1 HAR `6 AM 10: Richard W Stewart Solicitor aT,E Y..A .M r ;UMBE ?L, NU :OUNP' PENNSYLVANIA Ability Recovery Services, LLC Case Number vs. Lisa Buffington 2014-368 SHERIFF'S RETURN OF SERVICE 03/04/2014 09:49 AM -Jason Kinsler, 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, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kimberly Whitaker, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. JASO KIN E , DEPUTY SO ANSWERS, March 05, 2014 RONKK R ANDERSON, SHERIFF ;cur n.,Sheri `aosoh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION ABILITY RECOVERY SERVICES, LLC P.O. BOX 4031 WYOMING, PA 18644 Plaintiff vs. LISA BUFFINGTON 1708 HUMMEL AVENUE, APT. A CAMP HILL, PA 17011 Defendant and MEMBERS FIRST CREDIT UNION 1166 FOXMOOR VILLAGE CARLISLE, PA 17015 Garnishee PLAINTIFF'S INTERROGATORIES TO GARNISHEE TO MEMBERS FIRST CREDIT UNION (Garnishee): You are required to file answers to the following interrogatories within thirty (30) days after service upon you. Failure to do so may result in judgment against you: 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to the defendant on any negotiable or other written instrument, or did the defendant claim that you owed the defendant any money or were liable to the defendant for any reason? What is the total amount available in account(s)? 675 2. At the time you were served or at any subsequent time was there in your possession, custody or control or in the joint possession, custody or control of yourself and one or more other persons any property of any nature.owned solely or in part by the defendant? u c r. 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or in part by the defendant or in which defendant held or claimed any interest? (.) No. 14-368-CV RD. S te;Z:Cat.Q.0 MAR 4 201( 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? iv 0 5. At any time before or after you were served did the defendant transfer or deliver any property to you or to any person or place pursuant to your direction or consent, and, if so, what was the consideration therefore? Iv 10 6. At any time after you were served did you pay, transfer or deliver any money or property to the defendant or to any person or place pursuant to the defendant's direction or otherwise discharge any claim of the defendant against you? t",) 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, identify each account and state the reason for the exemption, the amount being withheld under each exemption and the entity electronically depositing those funds on a recurring basis. Ci If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. DATE: 2-24-14 RECEIVED MAR 4 2074 s T. Mulligan, Jr., squire ox 4031 ing, PA 18644 PA ID # 51794 (866) 760-6205 ext. 235 Attorney for Plaintiff VERIFICATION Understanding that false statements herein are made subject to the penalties of 18 PA.C.S. §4904, Unsworn Falsification to Authorities, I verify that I am k■AA-- of Garnishee in the above matter and that, after inquiry, the facts set forth in the foregoing Answers to Interrogatories are true, correct, and complete to the best of my knowledge, information, and belief, DATE: Signature i. IN THE COURT OF COMMON PLEAS HONOLTA CUMBERLAND COUNTY, PENNSYLVANIA2014 NAR 7 ply CIVIL DIVISION 1 4; 5 CHfri PLAINTIFF RLAND ABILITY RECOVERY SERVICES, LLC : PENNS YL VA N IA 4 coup7v P.O. BOX 4031 WYOMING, PA 18644 NO.: 14-368-CV vs. DEFENDANT LISA BUFFINGTON 1708 HUMMEL AVENUE, APT. A CAMP HILL, PA 17011 and GARNISHEE MEMBERS FIRST CREDIT UNION 1166 WALNUT BOTTOM ROAD CARLISLE, PA 17015 PRAECIPE TO DISCONTINUE ATTCHMENT AGAINST MEMBERS FIRST CREDDIT UNION, ONLY TO THE PROTHONOTARY: Kindly attachment discontinued against Garnishee, Members First Credit Union, Garnishee only, and give notice to all parties pursuant to Pa. R.C.P. 236. Date: 3 T. Mulligan, J -)1,‘ use Counsel for Plaintiff P.O. Box 4031, Wyoming, PA 18644 (570) 207-1892 ext. 235 ATTACHMENT DISCONTINUED Now, this ) I day of 6061 , 2014, the attachment is discontinued against Members First Credit Union, Garnishee only, is discontinued. Notice is given to all parties pursuant to PA. R.C.P. 236. Prothonotary awti 49 011&# Sle3)() SOL/5 i Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE PRO I H' {J C t,,: l 201 11AR -14 AM 10: 1:4 aiMBLRLANO LULN ` PENNSYLVANIA Ability Recovery Services, LLC vs. Lisa Buffington Case Number 2014 -368 SHERIFF'S RETURN OF SERVICE 03/04/2014 09:49 AM - Jason Kinsler, 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, 1711 Spring Road, North Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to Kimberly Whitaker, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. 03/05/2014 05:09 PM - Dawn Kell, Deputy , being duly sworn according to law, states that on March 05, 2014 at 5:09 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: Lisa Buffington at 1708 Hummel Ave, Apt. A, Lower Allen Township, Camp Hill, PA 17011, 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 March 7, 2014. 03/14/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ is returned STAYED. Defendant and plaintiffs attorney have entered into a payment arrangement. SHERIFF COST: $137.14 SO ANSWERS, March 14, 2014 RONN r R ANDERSON, SHERIFF (c) CountySu to She f, Te eosoff, .,,. as . sue u yd. *, 3o a9s-1