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HomeMy WebLinkAbout10-3586 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SLM FINANCIAL CORPORATION 12061 Blumont Way Reston, VA 20190 Plaintiff vs. DENITA SAMUELS 4815-8 EAST TRINDLE ROAD MECHANICSBURG PA 17050-3709 °n a Fn 3 w i4 e C,v l ?---lw'm Defendant CIVIL ACTION : NO: 10 - 35$(,,0 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 to Defend are served, by entering a written appearance personally or by an 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 61--S-) 4AA.oo PA ATrl C* 5877 eaya93q ti" S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SLM FINANCIAL CORPORATION _ CIVIL ACTION 12061 Blumont Way Reston, VA 20190 Plaintiff vs. NO: DENITA SAMUELS 4815-8 EAST TRINDLE ROAD MECHANICSBURG PA 17050-3709 Defendant : COMPLAINT Plaintiff, Salle Mae, Inc. Administrator and agent for SLM Education Loan Corporation, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, Salle Mae, Inc. Administrator and agent for SLM Education Loan Corporation, (hereinafter "Plaintiff") is a Pennsylvania corporation with a principal place of business located at 12061 BLUMONT WAY RESTON, VA, 20190 2. The Defendant DENITA SAMUELS (hereinafter "Defendant") is an adult individual residing at 4815-8 EAST TRINDLE ROAD MECHANICSBURG PA 17050-3709. 3. The defendant, for valuable consideration received, executed and delivered to plaintiff a promissory note for the payment of tuition under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. 4. Contrary to the terms of the aforesaid promissory note, the defendant failed to make the required payments when due as a result of which the unpaid balance of $15,970.87 became due and payable. 5. As a result of defendant's default, defendant is indebted to plaintiff in the amount of $15,970.87. 6. Plaintiff has made demand upon the defendant for payment of the amount due but the defendant has failed and refused and still refuses to pay the said sum of any part thereof. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $15,970.87 plus costs of suit and any other relief as the Court deems just and appropriate. Edwin A. Abrahamsen Assoc. Michael F. Ratchford, squire Heather K. Woodruf ,Esquire Attorney I.D. Nos.- 86285/207805 120 North Keyse Ave. Scranton, PA 1 504 mratchford@e -law.com hwoodruff@e -law.com Phone: 570-558-5510 Fax: 570-558-5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, Salle Mae, Inc. Administrator and agent for SLM Education Loan Corporation, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SLM Financial Corp. vs. Denita Samuels ~¢~tisitr of ~.~nr~Grt~l,~~~ 'C> - , , s~Ffl~E Jr?rESrERIFF SHERIFF'S RETURN OF SERVICE . ~IL~f, 1;4 ,,L . ~ :4 ZDI~ JAL -1 Pr' Z: ~Z c~r,~.~W ; ,~ c.;~~v Case Number 2010-3586 06/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Denita Samules, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Denita Samuels. Request for service at 4518-8 E. Trindle Road, Mechanicsburg, PA 17050 is vacant. Landlord advised Deputies, Denita Samules is thought to be residing in Maryland. However, to date The Mechanicsburg Postmaster has not been able to provide a good address for Denita Samuels. SHERIFF COST: $37.00 June 30, 2010 SO ANSWERS, ~"' F RON R ANDERSON, SHERIFF ,o) CountySuite St:enfl. Tetecsofi. Inc- David -D. Buelr Prothonotary Office ofthe Prothonotary Cuin6 errand County, Pennsy[vania 7(yrkS. So(tonage, ESQ, Solicitor �U ..:350.0 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28T" DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 ® CarCrsfe, P.,q 0 Thone 717 240-6195 0 Ea:, -.717 240-6573