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Home My WebLink About10-5470Blatt, Hasenmiller, Leibaker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney LID #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 ext. 4151 - _a Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. c As DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. MILEY C SHEAFFER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10 - 5470 (2IVI I Term 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant. 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, 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. LAWYER REFERRAL SERVICE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 0 02, 00 A0 A rfY ?'17/ Z- 2511005 PPTCPADI AVISO Le han demandado a usted en la corte. Si usted quiere defen derse de estas demandas expuestas en las paginas siguientes, usted tiene veinte dias de plazo al partir de la fecha de la demanda y la notificacion. Hase falta ascentar una comparencia escrita o en persona o con un aboga do y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisa do que si usted no se de fiende la corte tomara medidas y puede continuar la demanda en contra suva sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propieda des u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 Gregory R. Dye Attorney #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. C/o Blatt, Hasenmiller, Leibsker & Moore, LLC Plaintiff, vs. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. COMPLAINT Plaintiff DELL FINANCIAL SERVICES L.L.C., claims as follows: 1. The Defendant(s), MILEY C SHEAFFER, is a resident of Cumberland County, Pennsylvania. 2. The Defendant(s) opened an account agreeing to make monthly payments as required by the terms of the account, for purchases charged to the account. 3. The Defendant(s) did make purchases and charged same to the account but failed to make the monthly payments called for on the account. There is a balance due and owing of $2196.40. 4. Plaintiff declared Defendant(s) to be in default and demands payment of the balance. 2511005 PPTCOCCI WHEREFORE, the Plaintiff, DELL FINANCIAL SERVICES L.L.C., prays for judgment in its favor and against Defendant(s), MILEY C SHEAFFER in the amount of $2196.40, plus costs. Respectfully DELL FINANi One of its Attorneys Daniel Santucci, Attorney No. 92800 Gregory R. Dye Attorney #205316 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 (800) 850-1079 Dated: June 25, 2010 VERIFICATION the undersigned attorney for the Plaintiff, hereby verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based upon information provided by the Plaintiff, that the Plaintiff is presently located outside of this jurisdiction, and that in order to file the within document in an expedient and timely manner I am authorized to sign this verification on behalf of the Plaintiff. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsifications to au PPTXVERI Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 DELL FINANCIAL SERVICES L.L.C. Gregory R. Dye, Attorney I.D. #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 800-850-1079 DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: June 25, 2010 2511005 PPTJCAMI INNINININFAN III I 111111 By: Gregory R. Dye Exhibit A PPTXEXAI YUFlCATION The undersigned hereby verifies that: 1. I am employed by Plaintiff and am authorized to make this Verification on behalf of Plaintiff DELL FINANCIAL SERVICES L.L.C.. 2. 1 reviewed the following [check all that are applicable]: [) (a) computerized documents; [ l (b) hard copy of documents; and [X) (c) other (specify) computerized account data relating to Account No. 879450129003031229. The foregoing Account was opened on November 11, 2002 in the name(s) of Defendant(s) MILEY C SHEAFFER. 3. Based on my review of the foregoing documents, there is due and payable: the principal sum of $2196.40 which is calculated as the original creditor's chargeoff balance less any payments received The information that I reviewed were provided by the original creditor and or its assignees. 4. Based on my review of the foregoing documents, there are no payments that have not been credited to Defendant(s). 5. The facts set forth in this Verification are true and correct to the best of my knowledge, information and belief. This Verification is made subject to the penalties for making an unworn falsification to authorizes in violation of 18 Pa.C.S. Section 4904. ,4 Signature Print Signature Date: MAY 7 201h OjIWASS ?s? c°- ?, zo» PPTXNIVI 2511005 1 00011 Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. # 92800 Gregory R. Dye Attorney I.D #205316 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 610-902-0644 Attorney for Plaintiff, DELL FINANCIAL SERVICES L.L.C. DELL FINANCIAL SERVICES L.L.C. c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Plaintiff, vs. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. 10 -506 0-M Tarn PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Kindly ENTER my appearance in the above-captioned matter on behalf of PLAINTIFF DELL FINANCIAL SERVICES L.L.C.. Papers may be served at the address set forth below: _a 0 Blatt, Hasenmiller, Leibsker & Moore, LLC 5 Great Valley Parkway, Suite 100 Malvern, PA 19355 Telephone Number: 1-610-902-0644 ext. 4151 z Dated: June 25, 2010 2511005 PPTXPEAI Wxll? no By: BLATT, W & MOORE, Gregory R. Dye LEIBSKER SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FlLea-C` 1CE Sheriff ^:.10TAW at C [till Jody S Smith ?? 8: k? Chief Deputy o su -9 Richard W Stewart w i,rJl}(?tTY Solicitor t :c? . ::?t C1I1tA?3-Vf?1V1A Dell Financial Services LLC Case Number vs. 2010-5470 Miley C. Sheaffer SHERIFF'S RETURN OF SERVICE 09/03/2010 08:15 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on September 3, 2010 at 2015 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Miley C. Sheaffer, by making known unto herself personally, at 6222 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. STEP N BENDER, DEPUTY SHERIFF COST: $37.00 September 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c) Countysuite Sheriff. Teleosoft. inc Blatt, Hasenmiller, Lelbsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci DELL FINANCIAL SERVICES LLC Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 DELL FINANCIAL SERVICES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, vs. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). By: PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the DEFENDANT MILEY C SHEAFFER in this matter in the amount of $2,196.40 plus court costs. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1(a)(2) was mailed separately to each defendant on 2/21/11 by regular mail. A true and correct copy of each Notice is attached hereto. Dated: March 4, 2011 2511005 PPTJPFJI 11111111111 IN 111X1111111INIIIIIII111111111IIII IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION -U No. 10-5470-CIVL TERM ?0 rn CD += n-Y Respectfully subm BLATT, HASENIyyI'LL,,IrR, LEIS R & MOORE, LL / e? H?a?s ?' FIr.E IY1 `d I ?C DELL FINANCIAL SERVICES LLC Plaintiff, VS. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION No. No. 10-5470-CIVL TERM TO: MILEY C SHEAFFER NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Default Judgment has been entered against you in the above proceeding. PROTHONOTARY 4 Dated: By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record for Plaintiff: Blatt, Hasenmiller, Leibsker & Moore, LLC Daniel Santucci Attorney I.D. #92800 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 2511005 PPTNDJNI 111111111111 1111111111111111 IN 111111111111111111111I I I IN I Blatt, Hasenmiller, Leibsker & Moore, LLC Attorney for Plaintiff, Daniel Santucci, Attorney I.D. #92800 DELL FINANCIAL SERVICES LLC Gregory R. Dye, Attorney I.D. #205316 1835 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 DELL FINANCIAL SERVICES LLC c/o Blatt, Hasenmiller, Leibsker & Moore, LLC 1835 Market Street, Suite 501 Philadelphia, PA 19103 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION vs. MILEY C SHEAFFER 6222 STANFORD CT MECHANICSBURG PA 17050-2368 Defendant(s). No. 10-5470-CIVL TERM AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: County of Chester: I, Daniel Santucci/Gregory R. Dye, being duly sworn according to law, depose and say I am the attorney for Plaintiff and I am authorzied to make this affidavit on Plaintiff's behalf. I hereby certify that the Defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Servicemembers' Civil Relief Act of 2004 and any amendments thereto. I also herby certify that the statements made in the foregoing Affidavit of Non-Military Service are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. , LEIBSKER Dated: March 4, 2011 By: 2511005 PPTJCAMI 111111111111111IN IN IN IN IN 11111111111111111111111111 IIII Gregory R. Dye DELL' FINANCIAL SERVICES LLC. Plaintiff, IN THE COURT OF COMMON PLEAS VS. MILEYC SHEAFFER - 6222 STANFORD CT MECHANICSBURG PA 17050=2366 CUMBER'LAN'D COUNTY, PA CIVIL ACTION Defendant(s). No. 10-5470-CIVL TERM TO: MILEY C SHEAFFER Date of Notice: February 21, 2011 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 YOUR 'DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. 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 I'MPO'RTANT 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 MAYBE A13:LE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH 'BEDFORD STREET CARLISLE, PA 17013 (717) 267-2032 BL,ATT$ HASENMILLER,- LEIBSKER & MOORE, !L C By: Daniel Santucci 183,5 Market Street, Suite 501 Philadelphia, PA 19103 800-850-1079 This is a communication from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2511005 P'PTNLRSI j?N (?I II I'I??IiI ?? ? ??? ??? INII IINI VIII ?IIHI VIII ?NIII III IIII WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-5470 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DELL FINANCIAL SERVICES L.L.C. Plaintiff (s) From MILEY C SHEAFFER, 6222 STANFORD COURT, MECHANICSBURG, PA 17050 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: AMERICHOICE FEDERAL CREDIT UNION, 20 SPORTING GREEN DRIVE, MECHANICSBURG, PA 17050 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 $2,196.40 Interest Atty's Comm % Atty Paid $170.00 Plaintiff Paid Date: AUGUST 12, 2011 L.L. $.50 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: Name DANIEL SANTUCCI, ESQUIRE Address: BLATT, HASENMILLER, LEIBSKER & MOORE LLC 1835 MARKET STREET, SUITE 501 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-564-1567 Supreme Court ID No. 92800 Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION PROFCIPF FAR WRIT nF FYF1_1 ITION DELL FINANCIAL SERVICES L.L.C. Plaintiff VS. MILEY C SHEAFFER Address: to a 9 A 54n?-_v CL el+ N`{C?,h. P? ??osa rlcfenrfant TO THE PROTHONOTARY OF THE SAID COURT: ? Confessed Judgment ? Other =;0 cr) File No. 10-5470-CIVL TERM "r Amount Due 1 , I y G C' Interest `- y 2 t <? Atty's Comm P- / ) W Costs G The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon the following described property of the defendant(s) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description: supply four copies of lengthy personalty list) C7 + a) Z'. G,VU(jCA'10i C? ?derat 6/ CVO - aU fir. ?e . and all other properly of the defendant(s) in the possession, custody or control of the said ? (Indicate) Index this writ against the garnishee(s) as a lis pendens ag-st r I estate defendant(s) described in the attached exhibit. / Date M?-'& Signature: aru ? 101 , sa , d oUd-Lt 31.00 Cgr- Q a.00 ty.oo „? a so " ? n o ,w -PA Print Name: 1 0 Address: A) c? r F }? S )r 4, 1 OL11 1c, Attorney for: fie t , Telephone: 2 S' S. fi? Supreme Court ID No: 1. s?uti. a.ob W &- 2511005 PPTXCMPI rte- ?b?a?ao Wir t ? a F-ar Tnsu.•PA Meck SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff C THE PR0TH0N0Tl,,R Jody S Smith Chief Deputy Richard W Stewart Solicitor Dell Financial Services LLC vs. Miley C. Sheaffer 20! ! AUG 19 AM 8: 30 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2010-5470 SHERIFF'S RETURN OF SERVICE 08/18/2011 10:55 AM - Stephen Bender, 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, Americhoice FCU at 20 Sporting Green Drive, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County, by handing to Belinda Cadwallader, Customer Service Rep., 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. The writ of execution and notice to defendant was mailed on August 19, 2011 to Miley C. Sheaffer at 6222 Stanford Ct., Mechanicsburg PA 17050. SO ANSWERS, August 18, 2011 RON R ANDERSON, SHERIFF Step e Bender, eputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,y R Anderson enff ?„tt nt ;ur,rFrt,,, ? ? a0 1110ftci Jody S Smith '012 FEAR 23 Pal 2: 'IS Chief Deputy Richard W Stewart v1 HD CCJU 1 '`s Solicitor PENNSYLVANIA Dell Financial Services LLC Case 2010 Number umb vs. Miley C. Sheaffer SHERIFF'S RETURN OF SERVICE 08118/2011 10:55 Stephen Bender, Deputy, who being duly sworn in the hands, goods, chattels, rights, debts, credits, and monies dof he Defendant attached commanded all g possession, or control of the within named garnishee, Americhoice FCU at 20 Sporting Green Drive, i vei Cadwalla er, Spring Township, MpesonallythreeOcopies uof interrogatories to getherdwith thrreelt rue and attested Customer Service Rep., p copies of the Writ of Execution and made the contents there of known to her. The writ of execution and nctice to defendant was mailed on August 19, 2011 to Miley C. Sheaffer at 6222 Stanford Ct., 03/22/2012 Ronny R. Anderson, No action b iduly srn woven 6 morn hso law, states this writ of execution is on writ returned as ABANDONED SO ANSWERS, SHERIFF COST: $91.75 4RON ANDERSON, SHERIFF March 22, 2012 X24 (?; (moo,{n iy.jUltR_ Sher{?f, 1 e easoll_ Inc.