HomeMy WebLinkAbout10-5964SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
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Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
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Mazda American Credit
vs.
Leon G. Ramsey
Case Number
2010-5964
SHERIFF'S RETURN OF SERVICE
09/22/2010 06:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
22, 2010 at 1802 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Leon G. Ramsey, by making known unto himself personally, at 839 N. West Street,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $38.80
September 23, 2010
DENN FRY, DEP
SO ANSWERS,
RON R ANDERSON, SHERIFF
lc; County&Ae Sheriff. Te,eosoft, Inc.
,7
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
(215) 789-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
Attorneys for Plaintiff
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
LEON RAMSEY
Plaintiff, and against Defendant, LEON RAMSEY in the amount as follows:
Defendant(s) ,.,,, C")
PRAECIPE TO ENTER JUDGMENT
TO THE PROTHONOTARY: ?r' ,
No answer having been filed in the above Civil Action, kindly enter Judgment `in favor
Principal Amount $ 1342.41
Interest to Date $ 57.71
Costs $ 130.80
TOTAL $ 1530.92
MAURICE & W-EMAN, P.C.
BY:
JEEDLEMAN, ESQ.
for Plaintiff
Date: November 24, 2010
o ?`? a3°? gs
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
Our file no. 13932
(115) /89-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
(X) Notice is hereby given that a judgment in the above-captioned matter has
been entered against you in the amount of $1530.92 on Q
(X) A copy of all documents filed with the Prothonotary in support of the
within judgment is enclosed
no /Clerk
by:
If you have any questions regarding this matter, please contact the filing party:
Name: Joann Needleman, Esquire
Address: Suite 935, One Penn Center at Suburban Station
1617 J.F.K. Boulevard
Philadelphia, PA 19103
Telephone No.: 215-789-7155
(This Notice is given in accordance with Pa.R.C.P. §236)
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(L1J) /iSy-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
AFFIDAVIT OF MAIL SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that she is an attorney at law and that on October 27, 2010 she mailed a written Notice of
Intention to File the Praecipe to Defendant, LEON RAMSEY, at 839 NORTH WEST STREET,
CARLISLE, PA 17013 by regular mail.
MAURICE &
SWORN TO ANSUBSCRIBED
, 20?
4arNy e me this ay
Public
NWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
LANEASE SATES, Notary
Public
7my ity of Ph deiphia, Phila. County
o mmission Ex A ust 13, 2014
BY:
LEMAN, P.C.
11EEDLEMAN, ESQ.
for Plaintiff
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) 789-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT
It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on
October 27, 2010 to Defendant, LEON RAMSEY , against whom judgment is to be entered after
the default occurred and at least ten (10) days prior to the date of the filing of the Praecipe. A
copy of said Notice dated October 27, 2010 a copy of the mailing to the Defendant and affidavits
of service are all attached hereto.
MAURICE,.-TP?DLEMAN, P.C.
BY:
\'EEDLEMAN, ESQ.
for Plaintiff
Date: November 24, 2010
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
(215) 789-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
CERTIFICATION OF ADDRESSES
It is hereby certified that the parties have the following addresses:
Plaintiff: FORD MOTOR CREDIT COMPANY
P.O. Box 6058
MESA AZ 85216
Defendant: LEON RAMSEY,
839 NORTH WEST STREET,
CARLISLE, PA 17013
MAURICE &^EDLEMAN, P.C.
BY:
JO`AVV NEEDLEMAN, ESQ.
Att ev for Plaintiff
Date: November 24, 2010
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 19103
Attorneys for Plaintiff
1J) "/?iy-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
Defendant(s)
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF PENNSYLVANIA
COUNTY OF PHILADELPHIA
SS.
I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and
says that he/she represents the Plaintiff in the above entitled case and that Defendant, LEON
RAMSEY, is over 18 years of age; the occupation of Defendant is unknown and to the best of
Plaintiffs knowledge, information and belief, Defendant is not in the military service of the
United States, nor any State of Territory thereof or its Allies as defined in the Soldiers' and
Sailors' Civil Relief Act of 1940 and the amendments thereto.
MAURICE & NEFPLEMAN, P.C.
BY:
JOANPfyEEDLEMAN, ESQ.
Attornfor Plaintiff
SWORN TO AND SUBSCRIBED
b fore me this (*day
of \)WAKb"r, 2040.
Not ry Public
W ALTH OF PENNSYLVANIA
NOTARIAL SEAL
LANEASE BATES, Notary Public
Clty of Phila fthia, Phila. County
Cominiaaion iris A 13.2014
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
?y?tm °€ C?uaobrr
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor M C5 or TME sfw rr-
t39a
Mazda American Credit
vs.
Leon G. Ramsey
Case Number
2010-5964
SHERIFF'S RETURN OF SERVICE
09/22/2010 06:02 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
22, 2010 at 1802 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Leon G. Ramsey, by making known unto himself personally, at 839 N. West Street,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $38.80
September 23, 2010
DENN? FRY, DEP
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
;c -0ur-? SWq Sher.-K. 1'e±e3sott. Inc.
October 27, 2010
Attorneys at law
Suite 935, One Palo Center
1617 John F. Kennedy Blvd.
Philadelphia, PA 19103
141.215.665.1133
fay 215.563.8970
www.mnlawpc.cam
Donald S. Maurice
Member NJ Bar
Road Certified
Creditors' Rights low
American Board of Certification
Joann Needleman
Member PA B NJ Bar
Thomas B. Deminrzyk
Member Nl, NY & PA Bar
LEON RAMSEY
839 NORTH WEST STREET
CARLISLE, PA 17013
Our File No. 13932
RE: MAZDA AMERICAN CREDIT v. LEON RAMSEY
CUMBERLAND COUNTY COURT OF COMMON PLEAS,
CASE NO. 10-5964
Dear Mr/Mrs/Ms RAMSEY:
Enclosed please find a ten (10) day notice of default which is self-
explanatory. This is being served upon you due to your failure to respond to
Plaintiffs Complaint served upon you on September 22, 2010 . Unless an answer
to Plaintiff s Complaint is filed with the Court within ten (10) days from the date
of this notice, a default judgment may be entered against you.
If you would like to discuss a resolution to this matter, please call our office at
908-237-4571 and ask for Kim Crosby.
Thank you for your.prompt attention to this matter.
Very truly yours,
MAURICE & NEEDLEMAN, P.C.
Esq.
New Jersey Office
Maurice :'Needleman, P.C.
Suite 2007
5 Walter E. Farms Blvd.
Flemington, NJ 08822
tel. 908237.4550
fax 908237.4551
Eric
THIS CORRESPONDENCE IS AN ATTEMPT TO COLLECT A
DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE. THIS FIRM IS A DEBT COLLECTOR
MAURICE & NEEDLEMAN, P.C.
BY: Joann Needleman, Esq.
Identification No. 74276
935 One Penn Center
1617 John F. Kennedy Blvd
Philadelphia, PA 191.03
Attorneys for Plaintiff
15) 7119-7151
MAZDA AMERICAN CREDIT
Plaintiff
V.
LEON RAMSEY
CUMBERLAND COUNTY COURT OF
COMMON PLEAS
CASE NO. 10-5964
IMPORTANT NOTICE
TO: LEON RAMSEY DATE: October 27, 2010
839 NORTH WEST STREET
CARLISLE, PA 17013
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 JUDGEMENT MAY BE ENTERED AGAINST YOU WITHOUT A
HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT 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 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:
CUMBERLAND COUNTY BAR ASSOCIATION
LAWYER REFERRAL SERVICE
2 Liberty Avenue, Carlisle, PA 17013
(717) 249-3166
MAURI NEEDLEMAN, P.C.
BY
JOANN EDLEMAN, ESQUIRE
Attorne for Plaintiff
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request for Military status l lus response retlects active duty status including date the mdivld.11a.1was last on active
duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-
Departmerit of Defense Manpower Data Center Jun-08-2010 09:43:33
of-contact.
Military Status Report Pursuant to the Service Members
Civil Relief Act
Namet ' F_
Befui Date A ve Duty Status Active Duty End Date ?e
Acy
RAMSEY LEON Based on the information you have furnished, the DMDC does not possess any information
indicating the individual status.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the
information that you provided, the above is the current status of the individual as to all branches of the Uniformed
Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard).
Mary M. Snavely-Dixon
A
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the
Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on
eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as
amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of
thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has
experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative
asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are
strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the
"defenselink.mil" URL http://www.defenselink.mil/faq/l)is/PC09SLDR.html. If you have evidence the person is on active
duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you.
See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can
submit your request again at this Web site and we will provide a new certificate for that query.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than
30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized
by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for
purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard
Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes
Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who
is an active duty commissioned officer of the U.S. Public Health Service
tttr":://v 'v -v-.am d:. -?sc..miliapbii scrainopreDOn.ao[6/S; 201
[Zequest for Military
Statu
or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30
consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for
purposes of the SCRA who would not be reported as on Active Duty under this certificate.
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking
to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been
amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who
have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually
reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend
beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to
Service members under the SCRA are protected.
WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an
erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: SN I D7KP I R3
tttps:%iwww.dmdc.osd.miliappj,,scraipom-eport.dor(,/<;'20]C 12:4',:J' Pml'