The URL can be used to link to this page

Home My WebLink About02-5379CENTRAL PENNSYLVANIA COLLEGE : VS : VICTORIA M. O'SHEA : JAMES P. O'SItEA, JR. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 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 attorney and filing in writing with the court your defenses or objections 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 1-800-990-9108 CENTRAL PENNSYLVANIA COLLEGE : VS : VICTORIA M. O'SHEA : JAMES P. O'SHEA, JR. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT AND NOW, this ~ ~ c~t day of October, 2002 comes Central Pennsylvania College, above-named plaintiff, by and through its attorney, Gail Guida Souders, Esquire, and respectfully avers the following: aw Plaintiff is a corporation located at College Hill Road, Summerdale, Pennsylvania 17093. Defendant, Victoria M. O'Shea is an adult individual residing at 1940 Bullfrog Road, Fairfield, Pennsylvania 17320. Defendant, James P. O'Shea, Jr. is an adult individual residing at 1940 Bullfrog Road, Fairfield, Pennsylvania 17320. Defendant, Victoria M. O'Shea received a student loan from Plaintiff. See Exhibit A. Defendant, James P. O'Shea co-signed on the loan. See Exhibit A. Defendants defaulted on the loan. Plaintiff avers the amount due is $8,126.31, which is above the amount for mandatory arbitration. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and refused to pay the aforesaid balance to Plaintiff. 9. Pursuant to the financial agreement, the finance charge of 9.5 percent per year equals $830.29. WHEREFORE, Plaintiff respectfully requests that judgment be entered in favor of Plaintiff and against Defendants in the amount of $8,285.63 with continuing finance charges. Respectfully submitted, Gail Guida Souders Attorney for Plaintiff Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 717-236-6440 Identification #68740 DAUI'IIIH DEI'OSIT BANI( & 'Fl~.tfS'l' COS'II'ANY ' Educntioabi,mofCrcdltamountrequesIed$ Co-^pplieant Information Debt information DAtli'IIIN I)~J)OSiT IJAN.t~ A~D '~'J(us'r .~ .. ;C~ .......... , ¥, DAUPHIN DEPOSIT BANK AND TRUST COM1)ANY Member FDIC ORIGINAL Borrower. You also acknowledge r~ving a completed copy of the Note. w~mess / -L / ~2'o-Signer's Signa~cure /' NOTICE TO CO-SIGNER BORROWER'S NAME(S) Victoria M. 0'Shea ~OTE DATED You are bein~ asked to guarantee this debt. Think carefully before you do. If the Borrower doesn't pay the de.h~, you will haw :o. Be sure you, can afford to pay if you have to, and that you want to accept tiffs responsibility. · ,. · You may have to pay up to the full amount of the debt if the Borrower does not pay. You may also have to pay late'leas or col lection costs, which increase this amount. The Creditor can collect this debt from you w/thout first trying to collect from the Borrower. The Creditor can use the same collection methods against you that can be used against the Borrower, such as suing you, etc. If this debt is ever in default, that fact may become a part of your credit record. CO-$IG.;v~R'$ SURETY AGREEMENT: You the person (or persons) signing below as 'Co-Signer," promise to pay to us, or' to our order, the Amoun Financed, plus interest and other charges, as provided in the No e s gned by the Borrower identified above. You intend to be legally bound by all the terms o ihe Note, separately and together, wkh the Borrower. You are making th s promise to induce us to make the loan to the Borrower even though the proceeds wi[ be used only for the Borrower's benefit. You agree that we may seek immediate payment from you without making any prior demand for payment on th~ (SF~L) 1146 Old Rt 30. Cashtown, PA 17310 Street (SEAL) City B~te Zip Code Co~nonwealth of Pennsylvania: County of ~ ~.C'~¥,v% ~ : SS On this, the ~ day of 2~.O/v~ , 199~, before me, the undersigned officer, personally appeared,~ $ ~, D ~ke.% ~ . , known ~o me (or satisfactorily proven) to be the persons whose names are subscribed to the within instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. l~Orary Public ' - J-- ' Notarial Seal [William F, Paules, Jr., Notary Public M~ommisslon Expires Nov. 10, ~<~01 ! Cumberland Twp., AdamsCoun Member, P~of~ IN THE COURT OF COMMON PLEAN CIVIL ACTION - LAW NO, I VERIFY THAT TIlE .qTATEMEN'I,'S MADE IN THIS COMPLAINT ARE TRUE AND CORRECT. 1 UNDERSTANO THAT THE STATEMENTS HEREIN ARE MADE .~UI~JECT TO THE PENALTIES OF 18 PA.C.S.A. SECTION 4904 RELATING TO UNSWORN Pr'i~t~l Name ' /d Date CENTRAL PENNSYLVANIA COLLEGE VS VICTORIA M. O'SHEA JAMES P. O'SHEA, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 02-5379 Civil Term CERTIFICATE OF SERVICE ! hereby certify that on November 15, 2002 1 served the Civil Complaint upon the person and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403: Personal service by Paul D. Weachter, P.I.: Henrietta O'Shea 1940 Bullfrog Road Fairfield, PA 17320 Dated: Gail Guida Souders Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 717-236-6440 Paul D. Weachter, Private Investigator C661Jack Road hambemburg, PA 17201 1 Bondsman ,~ 24 Hour Service ~ Discount bonding Legal Eag[e Services Phone (717) 263-0041 TOLL FREE (888) 381-8916 Pager (717) 267-6672 Fax (717) 263-6423 PROCESS SERVER t¢ J CENTRAL PENNSYLVANIA COLLEGE : VS : VICTORIA M. O'SHEA : JAMES P. O'SHEA, JR. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5379 Civil Term TO: Victoria M. O'Shea and James P. O'Shea, Jr. DATE OF NOTICE: December 5, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT AN ANSWER TO Plaintiff's Complaint. UNLESS YOU ACT WITHIN 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 SNOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 1-800-990-9108 Gail Guida Souders Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 (717) 236-6440 Identification #68740 Attorney for Plaintiff CENTRAL PENNSYLVANIA COLLEGE VS VICTORIA M. O'SHEA JAMES P. O'SHEA, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PRAECIPE To Prothonotary: Please enter judgment in favor of plaintiff, Central Pennsylvania College and against defendants, Victoria M. O'Shea and James P. O'Shea for failure of defendants to plead to plaintiff, s complaint as follows: $8,285.63 plus costs. Date: Respectfully submitted, Gail Guida $ouders Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 717-236-6440 Identification #68740 Attorney for Plaintiff CENTRAL PENNSYLVANIA COLLEGE VS VICTORIA M. O'SHEA JAMES P. O'SHEA, JR. IN THE COURT OF CO~ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CERTIFICATE OF SERVIC~ The undersigned certifies that written notice of intention to file a praecipe for entry of judgment by default against defendants was mailed to defendants after the default ocurred and at least ten days prior to the filing of the praecipe for entry of judgment pursuant to Pa.R.Civ. P. 237.1. A true and correct copy of the notice is attached hereto as Exhibit A. l / Gall Gu~da ~ouders CENTRAL PENNSYLVANIA COLLEGE VS VICTORIA M. O'SHEA JAMES P. O'SHEA, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5379 Civil Term TO: Victoria M. O'Shea and James P. O'Shea, Jr. DATE OF NOTICE: December 5, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT AN ANSWER TO Plaintiff's Complaint. UNLESS YOU ACT WITHIN 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 1-800-990-9108 Gail Guida Souders Guida Law Offices, P.C. 503 North Front Street Harrisburg, PA 17101 (717) 236-6440 Identification #68740 Attorney for Plaintiff CENTRAL PENNSYLVANIA COLLEGE VS VICTORIA M. O'SHEA JAHES P. O'SHEA, JR. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5379 Civil Term CERTIFICATE OF SERVICE I hereby certify that I am this 5th day of December, 2002, serving the Default Notice upon the persons and in the manner indicated below which service satisfies the requirements of Pennsylvania Rule of Civil Procedure, 403: Service by First Class U.S. Mail: Victoria M. O'Shea James P. O'Shea, Jr. 1940 Bullfrog Road Fairfield, PA 17320 il Guida Souders PRAECIPE FOR SATISFACTION CENTRAL PENNSYLVANIA COLLEGE PLAINTIFF VS VICTORIA O'SHEA JAMES O'SHEA DEFENDANT CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - MONEY JUDGMENT No. 02-5379 To Prothonotary: Please SATISFY the judgment against VICTORIA O'SHEA AND JAMES O'SHEA Date= December 8, 2004 Respectfully submitted, Gall Guida Souders Guida Law Offices, P.C. 111 Locust Street Harrisburg, PA 17101 717-236-6440 Identification #68740 Attorney for Plaintiff