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Home My WebLink About10-6558SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4~~yit4~ ~~ ~ttinL fr~~~ 0 UFFIGE GF -~~ g!^ERIFF FI~.EC~'~fi~=ICE fi ~ ~'~°~E ~'~~?TN~1~d~T~",~ 3° ~~~~ ~~~ 2 ~ ~~ ~t~ ~ ~ !``6~BE~c~.~~<C~ CI~i~~'"c ~~°,,9~+c`~t *Jr as p, Ford Motor Credit Company vs. Renaldo Vazquez Case Number 2010-6558 SHERIFF'S RETURN OF SERVICE 10/18/2010 04:01 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 18, 2010 at 1601 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Renaldo Vazquez, by making known unto himself personally, at 609 Park Ridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 19, 2010 _/ .~ DENN FRY, DE TY SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosoft. h;c. 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 (21--)) /z59-/I--)l FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 "`- Cr. r- o r C) -?l (D -T1 PRAECIPE TO ENTER JUDGMENT: TO THE PROTHONOTARY: No answer having been filed in the above Civil Action, kindly enter Judgment in favor of Plaintiff, and against Defendant, REINALDO VAZQUEZ in the amount as follows: Principal Amount $ 12564.97 TOTAL $ 12564.97 P?k1 ;Llaa6 MAURI NEEDLEMAN, P.C. o?53L157 BY: A1010 M"I JOTA?W NEEDLEMAN, ESQ. Aift6mev for Plaintiff Date: January 6, 2011 MAURICE & NEEDLEMAN, P.C. Attorneys 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 Our file no. 12492 (1.15) 789-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 (X) Notice is hereby given that a judgment in the above-caption matter has been entered against you in the amount of $12693.97 on (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclose othon tary/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 1J) /z59 /1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 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 November 29, 2010 she mailed a written Notice of Intention to File the Praecipe to Defendant, REINALDO VAZQUEZ, at 609 PARK RIDGE DR. , MECHANICSBURG, PA 17055 by regular mail. MAURICE & NkADLEMAN, P.C. BY: JEEDLEMAN, ESQ. for Plaintiff SWORN TO AND SUBSCRIBED before me this f,)*y of Dece.#-AA-, 20# o. Notary Public C t III COMMONWEALTH NOTARIAL SEAT. C. SUSAN TREPACZKA, Notary Public City of Philadelphia, Phila. County A My emmiscion I??S,March. 23, 2012 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 15) 7N9-7151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on November 29, 2010 to Defendant, REINALDO VAZQUEZ , 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 November 29, 2010 a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE & NEEDLEMAN, P.C. BY: ()Ik-- JOANYRREDLEMAN, ESQ. Attorney for Plaintiff Date: December 17, 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 (L15) "/2Sy-/151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 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: REINALDO VAZQUEZ, 609 PARK RIDGE DR., MECHANICSBURG, PA 17055 MAURICE & DLEMAN, P.C. BY: JOA NEEDLEMAN, ESQ. Attorney for Plaintiff Date: December 17, 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) /z59-/151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6558 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, REINALDO VAZQUEZ, 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 & NEEDLEMAN, P.C. BY: (,//K, JOA EDLEMAN, ESQ. Attorne for Plaintiff SWORN TO AND SUBSCRIBED before me this i Ilay of p?zrTbta, 204 Q Notary Public C? VANIA r?'AM014WEALTH OF PENNSYL NOTARIAL SEAL Public C. Sl1SAN TREPACZItA, Notary I City of Philadelphia, Phila. County n omr iasion „ s-? . 23 2012__ a'SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Ford Motor Credit Company vs Case Number . Renaldo Vazquez 2010-6558 SHERIFF'S RETURN OF SERVICE 10118/2010 04:01 PM - Dennis Fry, Deputy Sheriff, who being duly swom according to law, states that on October 18, 2010 at 1601 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Renaldo Vazquez, by making known unto himself personally, at 609 Park Ridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. DENN FRY, D TY SHERIFF COST: $37.00 October 19, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF November 17, 2010 Attorneys at Law Saito 935, One Penn Center 1617 John F. Kennedy Blvd. Philadelphia, PA 19103 iel.215.665.1133 fox 2115639970 www.malawpc.cam Donald S. Maurice Member NJ Bar Board Cartifiad (raditors' Rights Law American Board of (erfificmloo Joann Needleman Member PA & NJ Bar Thomas R. 0ominayk Member NJ, NY & PA Bar New Jersey Office Maurice & Needleman, P.C. Suite 2007 5 Waher E loran Blvd. Flemington, N106822 tel. 908.237.4550 fax 908.237.455) REINALDO VAZQUEZ 609 PARK RIDGE DR. MECHANICSBURG, PA 17055 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. REINALDO VAZQUEZ CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 10-6558 Dear Mr/Mrs/Ms VAZQUEZ: Our File No. 12492 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 October 18, 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. Joann eman, Esq. JN/dlh Enc 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 19103 Attorneys for Plaintiff 13) Rf9=1131 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 10-6555 IMPORTANT NOTICE TO: REINALDO VAZQUEZ DATE: November 17, 2010 609 PARK RIDGE DR. MECHANICSBURG, PA 17055 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 Attorney W Plaintiff MAURICE MAN, P.C. BY ( /ML JOANN MAN, ESQUIRE = CA) D c o oz- mmm = m z DZ0 Dmm -, zm ccoo-f0 °w;u M D z n F, 0) ; - M m - n-?z Duer- r- -AO ZU3 'U < _ c G?7 N ;u mf? G>pc DAN = -4 o = Cil - N - Cl) z n 35 o;G O-j -4 < y!t?c?OnO CO) -? owl(. • ?• rrr:? L UCS95oooszso zequest nor W tary status i tns response retlects active duty status including date he individual was las on active dui,-y, if it «vas within the preceding 367 days. For historical information, please contact the Service SCRA points- Department of Defense Manpower Data Center Dec-17-2009 07:58:13 of-contact. .Military Status Report Pursuant to the Service Members Civil Relief Act Last First/Middle Begin Dane Active Duty Stagy Ad?ive Duty End Date Agmrvice ? cy Name REINALDO Based on the information you have furnished, the DMDC does not possess any information VAZQUEZ indicating the individual status. 11 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 RN 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 hl!p://www.defenselink.mil/fag/Tis/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 1equest for Mili*.arv ?tatu" ,• car 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:OB2FBN73UT ittns:!,v,xk,N,,.dmd,.osd.mil/anni/scra/nonrenort.doFI2/17/200c' 10:58:21 AM' 1 MAURICE & NEEDLEMAN, P.C. BY: Joann Needleman, Esq. Identification No. 74276 935 One Penn Center 1617 John F. Kennedy Blvd Philadelphia, PA 19103 -OFFICE 0; t HELPROTH NOtARY Attorneys for Plaintiff '011 JAN 31 PM 7: n 7 CUMBERLAND COUNTY PENNSYLVANIA (11S) 89-/1S1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. REINALDO VAZQUEZ Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS Case No. 10-6558 PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the verification of the Plaintiff, FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, for that of the verification previously filed. Respectfully submitted, MAUR E NEEDLEMAN, P.C. JOANEEDLEMAN, ESQUIRE Attorn v for Plaintiff Date: January 11, 2011 CERTIFICATE OF SERVICE, I, Joann Needleman, Esq. hereby certify that on this date I have caused a true and correct copy of the foregoing Praecipe to Substitute Verification on behalf of FORD MOTOR CREDIT COMPANY, A Delaware Limited Liability Company, to be served by regular, first class mail, postage pre-paid upon: REINALDO VAZQUEZ 609 Park Ridge Dr. Mechanicsburg, Pa 17055 Respectfully Submitted, MAURICE & XEEDLEMAN, P.C. BY: edieman, Esquire for Plaintiff DATED: January 11, 2011 VERIFICATION I, Bev" VNWNW , verify that I am the Authorized Representative for Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company, and are duly authorized to take this verification on its behalf; that statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. These statements are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. . i"--z //" I B Representative of Plaintiff, FORD MOTOR CREDIT COMPANY LLC, A Delaware Limited Liability Company DATE: OCT 19 2010 REINALDO VAZQUEZ Our file no. 12492 48063000000039537924