Loading...
HomeMy WebLinkAbout11-3232SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Ford Motor Credit Company vs. Donald L. Boyer, III FILED-OFFICE OF THE PROTHONOTARY 2011 MAR 29 PM 1: 02 " CUMBERLAND COUNTY PENNSYLVANIA Case Number 2011-3232 SHERIFF'S RETURN OF SERVICE 03/25/2011 05:10 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 25, 2011 at 1710 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald L. Boyer III, by making known unto Jennifer Boyer, Wife of Defendant at 626 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. RYAN BURGETT, DEPUTY SHERIFF COST: $43.00 March 28, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF MAURICE & NEEDLEMAN, P.Qz- Attorneys for Plaintiff BY: Joann Needleman, Esq. h }Q: 31 Identification No. 74276 935 One Penn Center fitli?BERI.AND ?NIN 1 1617 John F. Kennedy Blvd BEN NSYL'4p' Philadelphia, PA 19103 (215) -/Z59- / 151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL 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, DONALD L BOYER III in the amount as follows: Principal Amount Interest to Date Payments $ 4357.60 $ 615.76 (Less $ 2600.00) TOTAL $ 2780.61 Date: July 21, 2011 MAURICE & NEEDLEMAN, P.C. BY: JOANN NEEDLEMAN, ESQ. Attorney for Plaintiff aM? g 14 00 19 70 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. 15247 (115) /z59-/1?1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $2780.61 on S (X) A copy of all documents filed with the Prothonotary in support the within judgment is enclosed. S P 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) /2SV-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL AFFIDAVIT OF MAIL SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she is an attorney at law and that on 4/27/2011 she mailed a written Notice of Intention to File the Praecipe to Defendant, DONALD L BOYER III, at 626 ERFORD RD, CAMP HILL, PA 17011 by regular mail. MAURI NEEDLEMAN, P.C. BY: OANN NEEDLEMAN, ESQ. Attorney for Plaintiff SWORN TO AND. SUBSCRIBED before me this` y 4otary 201 c ETTA ROBINSON FPHILADE TARIAL SEAL otary Public ITY, PHILADELPHIACOUNTY ion Expires Mat 21 2015 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 (LIJ) /ZSN-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL CERTIFICATION OF NOTICE TO ENTER DEFAULT JUDGMENT It is hereby certified that a written Notice of Intention to File the Praecipe was mailed on 4/27/2011 to Defendant, DONALD L BOYER III, 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 4/27/2011, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MA BY: & NEEDLEMAN, P.C. , ESQ. Date: July 21, 2011 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 FORD MOTOR CREDIT COMPANY, A DELAWARE', LIMITED LIABILITY COMPANY Plaintiff V. DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL 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: DONALD L BOYER III , 626 ERFORD RD, CAMP HILL, PA 17011 MAURICEA NEEDLEMAN, P.C. BY: NEEDLEMAN, ESQ. for Plaintiff Date: July 21, 2011 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) /2S9-/IDI FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v DONALD L III BOYER Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE STATE OF PENNSYLVANIA SS. COUNTY OF PHILADELPHIA I, JOANN NEEDLEMAN, ESQUIRE, being duly sworn according to law, deposes and says that she represents the Plaintiff in the above entitled case and that Defendant, DONALD L BOYER III , 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. MAURIOP/A VEEDLEMAN, P.C. BY: SWORN TO ANUBSCRIBED before m this ay f U, 1 2 01 Notary Public IfOANN NEEDLEMAN, ESQ. Attorney for Plaintiff RIAL SEAL TA ROBINSON ota Public PrPHILADELPHIA COUNTY FxPires Mai 23, 2015 Attorneys at Law rite 935, One Penn Center 317 John F. Kennedy Blvd. Philadelphia, PA 19103 tel. 215.665.1133 tax 215.563.8970 www.mnlawpc.com Donald S. Maurice Member NJ Bar Board Certified Creditors' Rights Law rican Board of Certification Joann Needleman Member PA & NJ Bar Thomas R. Domincryk Member NJ, NY & PA Bar Rachel Marin Member NY & NJ Bars New Jersey Office Maurice & Needleman, P.C. Suite 2007 5 Walter E. Foran Blvd. Flemington, NJ 08822 tel. 908.237.4550 tax 908.237.4551 April 27, 2011 DONALD L BOYER III 626 ERFORD RD CAMP HILL, PA 17011 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. DONALD L III BOYER CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 11-3232 CIVIL Dear Mr/Mrs/Ms BOYER III: Our File No. 15247 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 March 25, 2011 . 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 N00leman, 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 1-1)) /69-/IJJ FORD MOTOR. CREDIT COMPANY, A DELAWARE: LIMITED LIABILITY COMPANY Plaintiff v DONALD L III BOYER CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-3232 CIVIL IMPORTANT NOTICE TO: DONALD L BOYER III DATE: April 27, 2011 626 ERFORD RD CAMP HILL, PA 17011 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 MAURICE & NEEIILEMAN, P.C. BY ,... JOANN NEE - AN, ESQUIRE Attorney for Pla''' tiff ch c O ° m m Co -D m MZz DZO Z Oman ?ZO m wxm D z M 0 O O)o w rn? o = -v m = o ODD cm 0 > ;U (D CL - ^J = O .a N A D ? mN "Co 0 N Q N li"8606, o-? WM o r LW899000SZ80 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Feb-09-2011 08:07:00 Last First/Middle Begin Date Active Duty Status' Active Duty End Date Service Agenc Name y Based on the information you have furnished, the DMDC does not possess any information BOYER DONALD 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 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 hht p://www.defenselink.mil/f4`pis/P 09S .DR.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. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of-contact. 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 https://www.dmdc.osd.mil/appj/scra/popreport.do[2/9/2011 11:07:10 AM] Request for Military Status 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:A7VOJB9LHI https://www.dmdc.osd.mil/appj/scra/popreport.do[2/9/2011 11:07:10 AM] IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FORD MOTOR CREDIT COMPANY, a Delaware limited liability Company Plaintiff VS. DONALD L BOYER III Defendant : No. 11-3232 CIVIL :CIVIL ACTION PRAECIPE FOR SUBSTITUTION OF COUNSEL TO THE PROTHONOTARY: Kindly substitute the undersigned as counsel for the Plaintiff in the above entitled matter. The undersigned hereby consents to this substitution. Lloyd S. Markind, Esquire (ID # 52507) Superseding Attorney Markind Law Group, P.C. 102 Browning Lane, Bldg 13, Ste 1 Cherry Hill, NJ 08003 Dated: August 28, 2014 F ENO.: FT116367 Joann Needleman, Esquire* Withdrawing attorney Maurice & Needleman, P.C. 935 One Penn Center Philadelphia, PA 19103 ID#74276 Dated: August 28, 2014 * Signed with permission of Joann Needleman, Esq.