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Home My WebLink About11-3989IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC : 8875 AERO DR CIVIL ACTION SAN DIEGO CA 92123 Plaintiff , cn r N C) c? , VS. 3q$? ?H( n = NO: 11. ? F5 SONDRA REED C) , C) V71 4 199 ASHFORD DR - ENOLA PA 17025 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 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 aw'k !LOG.MQa all C kA 5ko36 J Q* Q5? 5(do State of PENNSYLVANIA COUNTY OF MIDLAND FUNDING LLC, Plaintiff -vs- COMPLAINT SONDRA REED, Defendant(s). 1. Plaintiff is the current owner of, and/or successor to, the obligation sued upon, and was assigned all the rights, title and interest to defendant's HSBC BANK NEVADA, N.A. account 5491098636860016 (MCM Number 8530705071) (hereinafter "the account"). 2. Upon information and belief, this action is based upon a credit agreement entered into between defendant(s) and the original credit grantor. 3. Upon information and belief, defendant(s) used or authorized the use of the credit account to obtain loans from the original credit grantor for the purpose of obtaining goods and/or services and/or cash advances. 4. Defendant(s) failed to make full payment of the amount owed on the account. 5. Upon information and belief, the last payment posted to the account on 2008-09-24. 6. The account shows that the defendant(s) owe(s) a balance of $14731.15. 7. Attached hereto, upon information and belief, is a true and correct copy of the credit agreement provided to plaintiff as either the actual agreement applicable to exemplar of such agreement By: NEVADA, N.A.. Page - 1 8530705071 AFFINDEBT E10-3253 3 Verification Ashley Hoffman, being duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ("MCM"), servicer of this account on behalf of plaintiff. I am authorized to make this verification on plaintiffs behalf. The facts set forth in the foregoing pleading are true and correct upon information and belief. APR 0 9 2011 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on 1? (Seal) ASHLEY MAE LASHINSKI omo Public-Miilnssota Notary es Jan,31, 2015 PA38 Edwin A. Abrahamsen & Associates, P.C. Public by Ashl ft Hoffman. I My commission expires: Page - 2 101"11,,,11 1®11"1„" 8530705071 AFFINDEBT E10-3253 Dept. 12421 PO Box 6o3 Oaks. PA 19456 ?ININIINIANNfI11NN IINN ¦NI?IIIIIINNINNIINIIIIINIIINNIIIIIIII 08-25-2010 #B WNHLTH 1032' - 3124 #0000 0853 0705 0717# SONDRA A REED 199 ASHFORD DR ENOLA, PA 170252303 Dear SONDRA REED, Midland Credit Management, Inc. has made several attempts to contact you regarding this account. This letter is to inform you that we are considering forwarding this account to an attorney with the intent 'icy he your last to initiate legal action to satisfy the debt. Upon receipt of this notice to work with us , please call immediately to discuss your options. 31w NCO°"t 9°Bs at3r>r11ey If we don't hear from you or receive payment by 09-24-2010, we may ""Ctan4Ntreportwill proceed with forwarding this account to an attorney. with * mi?dol What do you need to do to stop this process from continuing? you make m of your all t aY 1) Mail in $250 and call to set up our remaining payments or men (s) R ',;p+adit report rt vAll Witt be , 2) Call us today to see how to qualify for discounts and affordable s'Paid in Full'I* payment plans. LET US HELP YOU! Once the account goes to an attorney our flexible , options may no longer be available to you. There is still an opportunity to make arrangements with us. We encourage you to call us today: (800) 939-2353 CALL US TODAY! (800) 939-2353 Midland Credit Management (800) 939-2353 PLEASE SEE REVERSE SIDE FOR IMPORTANT INFORMATION AND Hours of Operation: ADDITIONAL DETAILS ABOUT YOUR ACCOUNT. M-Th 6am - 7pm; Fri 6am - Spm; * Your credit report will not be updated if the federal reporting Sat 6am - 2:30pm PST period has expired. Please tear off and rettirn lower portion with palment in the envelope provided tiMCM Account No.: 8530705071 Current Balance: $15,963.69 Payment Due Date: 09-24-2010 Amount Enclosed: Make check payable to. Midland Credit Management, Inc. RFC Midland Credit Management, Inc P.O. Box 60578 Los Angeles, CA 900600578 12 8530705071 7 1596369 092410 2 Q a 16321-3A69- 3124 Midland Credit Management, Inc. m C m Dept. 12421 PO Box 603 Oaks.. PA 19456 Please understand this communication is from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose. BILL OF SALE HSBC CARD SERVICES (111) INC. ("Seller"), for value received and pursuant to the terms and conditions of the Receivables Purchase Agreement ("Agreement') dated February 20, 2009 between Seller and Midland Funding, LLC ("Purchaser"), does hereby sell, assign and convey to Purchaser, its successor and assigns, all right, title and interest of Seller in and to those certain purchased receivables listed on the Sale File attached as Exhibit A, without recourse and without representation of, or warranty of, collectibility, or otherwise, except to the extent provided for within the Agreement. EXECUTED this 27`h day of April, 2009. HSBC CARD SERVICES (III) INC. By: Name: Susan Solomon Title: Vice President-Assistant Secretary zw LL-M mp°?.d°",.? ?e oM C.TiblebRWr'Y q SECURITY WTEREST CREp sCARD FRAUD re61„[ ?w? aaM CM1e2a a ?de Ponem?1 rywn pw?n1pwaeeY ,ww,en?wi, wiM m pv wrp?rl wwde?aulm0 ie aY?q?wK . fy UewnlunaN R mn?NwV a aMdbtle w`a ?wm??nn msq We?wMbwvpa deadwal?en?rw UPnalan ir,bb MplwmHwvdu? ?e? Mao?e,? canal ?aenswrtle u.a Rywury ( e ,agvl.Op RFaq'NYCke% aw r ??'8„?"°I eu. Via, xmr a..ae wlnman Pm.Y Sm?n'.n., °w°w?°? ADW-AL TERMS `RWRATbry A,ee.uw, A< MEW, rdbyrxe,aiYa,YU ?. bm?i Kbafm w ry ?np b Mewl wu iet?t?Illbm?nl Wib caa.r.e n.wa, w ?ra?Wmbry a?Neeem+wi np'°x°wmm.f^,'e .ate e?. WwR?anvab?? Ne? M^aWw e. Y ?ae"I ce,w? P-g Dad a,4 APpY Me wme??1aMwaaayF'°?aa"a ??pd??apPEa a.,n ?ede qa ar?m??" MOm ea?adm,?i b?a?`n?,we??imaphnyY?. wm?ww?iMab,?`r'waa ryriyU y r9 bwitrllada?m?a v?rwmak,wbu'^a?eFM qny aun ln.rb`aMiabbn? Ib 104 4 +" o,? Me a. rrb'eronw w row nw?n Mi+dmW am-a,+r bnwa wry ? ?eaapw„a., a Dem,y A,sbbbn Mw mnmmdeorl eu nWw W uEenm rdea d. mcp? OC IWb Tee wa? ?"'w.mm+w, 3 en,w,. -10rx OTHERIWCO TIOR }a,M d Aauun ?!.!!q,_fa4 r? rren wpxe?wnmb Kmuxn ° aK w ' Sda M„ mr veWV ame ven? ?AOreen?rra? bbr?blge? o Web ?wn mrn reMwP'srb eaxuetle A??amm Ew xouRMUUGrarHrs What TO Do N Thus s An Error In Your BIII ?MVJGRI $ ItEEPTHn RDTICEFCR in reaoa,d0?xm MA ,qew e,q IgTFY IIS IN CASE OF ERRORS OR OOESTMJRS A??? wmum? ?? wmraaw o b ?? ? Fa?? as ?,,.?YOw_ nzn N Maa Ww,maa W W blm OUR RIGXTS ANO OUR RESPON91BILnIFS PETER lag RECENE YOIAR MTarTEN ryOTCE: M.w ??? men:Wmmwi YeW nMirsbwem?age, A?rann"vvmmwwee rraeeeppvveewad.n ?Yw Mrve be Ga wsm,cl ?.w%`p'ie gmedbn eaY enxxvp M?ml+wwn, Wi MUCWeb aiiwarn?ab"/? Yax Cmiwtml wxba?mbiunYwwg niN•eQi Nw bw""in4Yuu pc n edn4aael. Hewvw. ,we e? naxn eowea n`olu?wery ?dbn ww ,e.ma.m a F? a ?'"?? ~?. ,.?,Ira? .mawnw?aabn SPECIAL RULES FOR CREW CARD PURCHASES RM °" of iM niw paa nwt bva ben nue na. C mrrta M Pmme Pmbaq m,aee wn c. H.Wa. ?a >4?i. e ,tr[s CARDMEMBER AGREEMENT AND DISCLOSURE STATEMENT ( IG ^?wrsa, caae.,me. ny??em ?,. bwyn. -eda req.mm yem.r. Meaa,eR. rieb,w a APR.?rn,me? wd""vim - ,A. 'W lia+arn ?? HSBC Car?Mti aW w ,n. Fe„aw, dPo,.m d daa Inaemen d V aemabna sn.n W.gV?w KCCUn OIIVl HSBC B,? ??dM?1ecw Fbrae q,M ,9nmMm lasar.alawrraic, bmem ou,a, ?dwe.be w any R?,?a A 2T01A (M) Ci AGREEMENT TO TERMS AND DEFIMTIONS ??v,limy ?cu. ?W?« "°ta4e•PCi?p .m w"YObolpa w°Cw«tl`? USNIG YOUR RS-CK?SWNT m air- '-L v. ?MM cNa ?.ew YOUR CREDIT d..«,s.KromM«!n ylK a.Yl? ? b ?.Iav?r?e ov,0lelen br IeaNlu r'vr"erau PAYMENT v??y«p??setl«.????.,".MmuaWN??.ponaa?eN".?M ?Fwxype4 aAUe uNw ?u tt•m eilMdarlEwvi',•wen?vlMMe?vn ure?b?wb,P ?enau?4 ?'?Y?e?e? MNnN.n?Yern I:I pm,ern v M p'.m? m.v In.n EIS. yov u-mum %v??d ? ?Bplwo u?om an v«r tlNFp m«u.q?? tN ro «r wu? a.rry A-w Fw. W° E?1Ww"?vb?1 °M.negro"i1.v on be Meive. °.N,rmE?rPax° '?' «.'?ebe?mPNm.. " p.«° D- E.a ,'•:.m.. ?mWV Mb«weei?'?ae BYer«?.q wll u,r lrn Y3ef"?.KYd? ?m Mi,p + W..«I by Yw E.N.awMNuN.vn vim .°eiwn o°yni eF.xwm-Y«'NM;.FAbe""?° u INTEREST RATES AND FIN Bk?SeP?" b -eS< si.: W YS N,YA'm?Nr?.'wee",ua?p ??tl?"?yep0.ry In"e. FN VNYbN Rw Awb-.a r xmmil? p`Xbti 'Sb ul1b1wi? Elm. Q N?w?N?R II?.?«I M.me?Aeflwul'aa.m ve?mbrnel'M.. WI ???iMi bb . •-.w y',ur.P,Fyunple o? -T FEES FBI b me Nuxw NpPl..l v ,.? ?w r+-Wbla"bJCO -.Aai.l`"Ta. ?..ylr.,. F« p ?m? ?bn M?is? Pv?? b uevZcuu,.?V"q I?ne ppN?x FE! _U?r.? a p?_ ?' MewnX ?+Mla+w.°esfwn`? Y'°mem tl«WTpOpNp«MU« sav Wiwba?vrE h?ra ntlt°In? F.«N." aNr".a RNWIbd..r11N. F« W?viw p-Y v ap,n ?n.nwl hvibluf??'" qc? M1°° ?"•?.?I-p« Y4M rwM4n ygOPU•v?`ie?iw'mevaN R.Rnr,.O CI.b1 F ? 4 eW ..n...bn. " °Wa: e,tb ' -gib P. sryrP:e M-e -M MY99 , ,? ?p i ? ??b me' mP?a?m e"fea`?s e?vinYo DOE ?vV?evm1e"o a «F. eilx,p buem-t. « g1. 0%tlFwN SNbrcm 4.m' cM° "et Norse b e,,,, Mw-. ACCOWI RENEWAL. CLOSURE ANO TERTNN11lION M??r ?nW?iv,uM,an ,niVerm<om nfwlatlA°upN'EilaE ie? .wculi b ?°°b N ?? ?C•Nbl tlYNr? trtN tie e?bM"ro n.r?s me"b? °fa?nt AwN.% -4- nil FwF ba«MNbea ?e M?wlltlb? a°Fw.b". pu mNMU«wiCNv Mp. Dww A.R MIDLAND FUNDING LLC In the Court of Common Pleas of Cumberland County, Pennsylvania Plaintiff Civil Division vs. NO: 11-3989 SONDRA REED 11 READING ST Steelton PA 17113 Praecipe to Reinstate Civil Complaint Defendant To the Prothonotary of Cumberland County Pennsylvania: Please enter the above Praecipe to Reinstate the Civil Complaint. Thank you, Lawyer ID # 86285 1 1 1"/ / (--V 64, A41 e . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV FILED- ANNE PRO MIDLAND FUNDING LLC Plaintiff vs. SONDRA REED 250 CLOVERLANE DR MANCHESTER PA 17345 Defendant TO THE CLERK OF JUDICIAL RECORDS: CUMBERLAND COUNT) PENNSYLVANIA PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the amount of $14,731.15. Notice of the intent to file a default judgment was served upon the Defendant on June 12, 2012. A copy of the Notice of Intent to Take Default Judgment is attacl hereto and marked Exhibit "A." NO: 11-3989-CIVIL Edwin Al Abrahamsen & Apwtiates, P.C. *464 F atc ford, E ui AttornI.D. No.: 8628 71 Attorney for Plaintiff C JUDGMENT AND NOW, this day of 2011; Judgment is hereby entered in fi of the Plaintiff, MIDLAND FUNDING LLC and against the Defendant, SONDRAIREED in amount of $14,731.15 for failure to respond to Plaintiff's Complaint. PROTHONOTARY CIVIL DIVISION 2012 JUL 27 PM 2: 2 sold. a? ?j$GSV 9 J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC Plaintiff CIVIL DIVISION vs. SONDRA REED NO: 11-3989-CIVIL 250 CLOVERLANE DR MANCHESTER PA 17345 Defendant CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated bellow, I serva copy of the Praecipe for Entry of Default Judgment in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: SONDRA REED 250 CLOVERLANE DR MANCHESTER PA 17345 Edwin A. Abrahamsen & Associates, F.C. Date: July 23, 2012 / 1141 ByIA, Milthael f 'Ratchford, Es re Attorney I.D. No.: 86285 120 N. Keyser Avenue Scranton, PA 18504 (570) 558-5510 MIDLAND FUNDING LLC In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division vs. SONDRA REED 250 CLOVERLANE DR. MANCHESTER PA 17345 NO: 11-3989-CIVIL Defendant NOTICE OF FILING JUDGMENT Notice is hereby given that a money judgment in the above-captioned mattr h been entered against you in the amount of $ 1 y. 3 1. ( S on By: If you have any questions regarding this notice, please contact the filing party: Edwin A. Abrahamsen & Associates 120 N. Keyser Avenue Scranton, PA 18504 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) B7VM A AORANAMSON MIQIAELF. RATOIFORD MNA Mmk"S 1J -191 THE LAW OFFICE OF MVIN A.ABR.3ILAMSEfN & SSOCUTSS, PC WWWEAA-LAW CUM June 12, 2012 SONDRA REED 250 CLOVERLANE DR MANCHEs'rER PA 17345 Re: MIDLAND FUNDING LLC v. SONDRA REED CUMBERLAND County Civil Action No.: 11-3989-CIVIL Our file No.: 1:10-3253ND Dear SONDRA REED: Enclosed please rind the Ten Day Notice of Intent to Take Default in regard to the above- noted matter. Please act accordingly. If you have any questions or wish to discuss your outstanding account, please contact me at (570) 558-5510. Edwin A. Abrahamsen & Assoei Michael F. Ratchford, Esq Enclosure This is a communication from a debt collector in an attempt to collect A debt. Any information will be used for that purpose. 120 k KEYSER AVE SCRANTON, 1A 11501 (r) 570.558.5510 (q 570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LLC Plaintiff : CIVIL: ACTION vs. SONDRA REED : NO: 11-3989-CIVIL Defendant : To: SONDRA RUED 250 CLOVERLANF, DR MANCHESTER PA 17345 Date of Notice: June 12. 2012 IMPORTAN'T' NOTICE PURSUAN"f 'I'O PA R C P 237 1 Lal YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN 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 HEAkJNG 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 BdLOW. 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. Dauphin County Sheriffs Office Market Streets Harrisburg, PA 17101 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MIDLAND FUNDING LIX CIVIL AC'T'ION Plaintiff vs. SONDRA REED NO: 11-3989-CIVIL Defendant CERIFICATE OF SERVICE I, Michael 1. Ratchford, Esquire, hereby certify that on June 12, 2012 1 servedla copy of the Ten Day Notice of Intent to Take Default in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: SONDRA REED 250 CLOVERLANE DR MANCHESTER PA 17345 Edwin A. Abrahamsen & Associates, P.C. Michael F. Ratchford, Esquire Attorney I.D. No.: 86285 120 N Keyser Avenue Scranton, PA 18504 (570) 558-5510 Department of Defense Manpower Data Center SWAN 40 purnod Repold to S 'V (Civil ReW Act Last Name: REED First Name: SONDRA Active Duty Status As Of: Jul-20-2012 Results as of 012 12:52:55 SCRA 222 NA NA No NA This reWWW refbdo dre 016w duals acb" duly etaWs based on ft AM" Duty SYWrs Date NA NA No NA This response retlecls where V* individual left active duly etatus wf i 367 days prep ft the Active Duty Staais Dace NA NA No.. NA This reWW= rSMK* whather tiro K*.-duW or h s&w unit has received ewiy nefficOm b report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you pro vicleri, trte above is the tatus of the individual on the active duty status date as to all brandm of the Undormed Services (Army, Navy, Marine Corps, Air Foroe, AA Public Hea , and Coast Guam). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report Active Duty. La"J e 1W Mary M. Snavely-Dixon, Director Departrnent of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and 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 Senvicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly kn n as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any ily member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitle 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: httpJ/www.defenselink.miVfagtpis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty tatus date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 52 (c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whethejr the individual + Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notifioetion to report for rive duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a CAN to active serv authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by IN President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard serve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissicined officer of the I.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). 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. SCRA protections are for Title 10 and Tide 14 active duty records for all the Uniformed Services nods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). 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 rvice. Furthemore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be included. but who a 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 the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the RA are protected WARNING: This certificate was provided based on a last name, SSN, and active duty staters date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: J189PTKPTT PRAECIPE FOR WRIT OF EXECUTION—(MONEY JUDGMENT)RULES PA.R.C.P.3252,3111 (a) MIDLAND FUNDING LLC In the Court of Common Pleas of Plaintiff : CUMBERLAND County,Pennsylvania . Civil Division co rri C (/) vs. . = SONDRA REED 250 CLOVERLANE DR NO 11-3989-CIVIL MANCHESTER PA 17345 .7 Defendant .: r= rx - vs. PRAECIPE FOR WRIT OF EXECUTION AND ATTACHMENT WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG,PA 17050 • Garnishee : (MONEY JUDGMENT) • To the Prothonotary:TO SATISFY THE JUDGMENT,ISSUE WRIT OF EXECUTON IN THE ABOVE MATTER (1) Directed to the Sheriff of CUMBERLAND County,Pennsylvania; (2) Against:SONDRA REED (3) And against:WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG,PA 17050 (4) and index this writ(a)against Defendant(s)(b)against WELLS FARGO 6416 CARLISLE PIKE STE 2100 MECHANICSBURG,PA 17050 Garnishee(s), as a lis pendens against the real property of the defendant(s)in the name of the Garnishee(s),any and all accounts of the defendant(s),in the possession of Garnishee,including but not limited to savings account balances;checking account balances;Certificates of Deposit; Money Market Accounts;contents of Safety Deposit Boxes.Defendant's SSN(s): ***-**-7897; (5) Judgment Amount $14,731.15 Interest $930.47 Payments $ Clerks Fee Sheriff $ Poundage $ Total $ (2) Date:August 15,2013 tag/.00 pb AT11� ®-- /03 75- ('Br j Micha:, F.Ratchford, Esq e 10,C Edwin A.Abrahamsen& •sso ates,P.C. /0.CO Attorney for Plaintiff ,50 " mratchford@eaa-law.c' t�9.� y8 �: 37 a.,;0-.3 fur Sc eft 1,16.9.3 pf-a4c�ay ),.:+6PP The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 Servicemembers 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 only 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 was on active duty for the active duty status date,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/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense 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 Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(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 or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). 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. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). 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 the SCRA extend beyond the last dates of active duty. Those who could 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 last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: G456P70B0001970 .1eA. MIDLAND FUNDING LLC • In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania Civil Division vs. • SONDRA REED • 250 CLOVERLANE DR : NO: 11-3989-CIVIL MANCHESTER PA 17345 : r • f `^ (/) Defendant : r— - Y ci 7 WELLS FARGO • c 6416 CARLISLE PIKE STE 2100 • > ry • MECHANICSBURG,PA 17050 c, Garnishee . • Praecipe for Entry of Appearance Kindly enter my appearance on behalf of MIDLAND FUNDING LLC in the above-captioned matter. Date:August 15, 2013 Agfrii � Signature- Print N. e. Michael F. Ratc ord Es.uire Address: 120 North Ke ser • enue Scranton PA 18 14 Telephone No: 570 558-;510 Ext. 120 Supreme Court ID No: 86 85 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 11-3989 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MIDLAND FUNDING LLC, Plaintiff(s) From SONDRA REED,250 Cloverlane Dr,Manchester,PA 17345 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: WELLS FARGO,6416 Carlilse Pike,Ste 2100,Mechancisburg,PA 17050 Any and all accounts of the defendant in the possession of the Garnishee,including but not limited to savings account balances; checking account balances; Certificates of Deposit; Money Market Accounts; contents of Safety Deposit Boxes,Defendant's SSN: ***-**-7897 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; (2) 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$14,731.15 Plaintiff Paid$ Interest -- $930.47 Attorney's Comm. % Law Library$.50 Attorney Paid$25'/..).5 Due Prothonotary$2.25 Other Costs$ Date: 9/30/13 I i __ _ _ . _'�. David D. Buell, Prothonotary B B . ; ` ii - . sill - Deputy REQUESTING PARTY: Name : MICHAEL F. RATCHFORD,ESQUIRE Address: EDWIN A.ABRAHAMSEN &ASSOCIATES,P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 Attorney for: PLAINTIFF Telephone: 570-558-5510 Ext.120 Supreme Court ID No. 86285 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff at umbel, Jody S Smith Chief Deputy _ ' 2 ' Richard W Stewart Solicitor, � ; = �U' °�F4 � I sO Midland Funding LLC vs. Case Number Sondra Reed 2011-3989 SHERIFF'S RETURN OF SERVICE 10/01/2013 12:33 PM -William Cline, 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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Deirde Strickler Chronister, Store Manager, 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 October 2, 2013 tp'S ra Reed at 250 Cloverlane Drive, Manchester, PA 17345. r2 LIAM LINE, DEPUTY SO ANSWERS, October 02, 2013 RONR ANDERSON, SHERIFF SIRLIN LESSER& BENSON,P.C. By: Jon C. Sirlin,Esquire Identification No.: 17498 123 South Broad Street,Suite 2100 Philadelphia,PA 19109 (215)864-9700 Attorney for Garnishee MIDLAND FUNDING,LLC : COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND vs. • ( f SONDRA REED : NO. 11-3989 c and -4 , • WELLS FARGO, GARNISHEE ENTRY OF APPEARANCE r- -4 TO THE PROTHONOTARY: Kindly enter my appearance on behalf Wells Fargo, Garnishee in the above- captioned matter. 11\ JON C. S Attorne, for arnishee Date: \V-1:3-- MIDLAND FUNDING LLC • In the Court of Common Pleas of Plaintiff : CUMBERLAND County,Pennsylvania : Civil Division vs. SONDRA REED • 250 CLOVERLANE DR NO: 11-3989-CIVIL MANCHESTER PA 17345 Defendant : Praecipe to Dissolve the Attachment gain vs. : Garnishee w _„ mtv WELLS FARGO • 6416 CARLISLE PIKE STE 2100 • -<1"' MECHANICSBURG, PA 17050 ? Garnishee z,o c P. • To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Dissolve the Attachment against Garnishee. Thank you, 4111 Mich:el F. Ratc ord, Esquire Edwin A. Abr. amsen&Associates, P.C. Lawyer ID# '6285 q.soj� a Ck" aacisq`i r' tiF 'li 2 may, SIRLIN LESSER& BENSON, P.C. B Jon C. Sirlin,Esquire, I.D.No.: 17498 ti.E',D v Ia 13 South Broad Street, Suite 2100 if' PROTIiONOTA Philadelphia,PA 19109 2Gi3OCT I I PM 1: 58 (215) 864-9700 Attorney for Garnishee CUMBERLAND COUNTY PENNSYLVANIA MIDLAND FUNDING,LLC COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. SONDRA REED NO. 11-3989 and WELLS FARGO, GARNISHEE ATTORNEY I.D.#17498 BILL OF COSTS OF GARNISHEE, WELLS FARGO Garnishee, Wells Fargo, hereby bills the following costs to the fund attached and will be satisfied therefrom, as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C.S.A Section 2503: $335.00 Notary Charges: 0.00 Entry of Appearance: $ 0.00 Answers to Interrogatories: $ 0.00 Order to Discontinue or Satisfy: $ 0.00 Other: 0.00 TO AL: $3 JON C. 1 IN Art, y for ishee Costs are hereby taxed in the amount of$ this day of ,2013. PROT OTARY BY: • •yam. � r MIDLAND FUNDING LLC •• : In the Court of Common Pleas of Plaintiff : CUMBERLAND County, Pennsylvania . Civil Division vs. SONDRA REED • : NO: 11-3989-CIVIL Defendant : . Satisfy the Judgment, Discontinue and End Case To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Satisfy the Judgment, Discontinue and End Case. %7 ---I -^Q C ' Thank you, 37 C-, Ai II ILAI • Michael ''. 'atchford, Esqui r- Edwin A. Abrahamsen & A•sociates, P.C. Lawyer ID # 86285 120 N. Keyser Avenue Scranton PA 18504 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY {f� PRO 3NON � yj, tl.�(�i,.. • li THE i- RO d E lONO fllf'4 l COIN vow 200 liAY 13 PM 3: 04 CUMBERLAND COUNTY PENNSYLVANIA OFFK E Or tNS Midland Funding LLC vs. Sondra Reed Case Number 2011-3989 SHERIFF'S RETURN OF SERVICE 10/01/2013 12:33 PM - William Cline, 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, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Deirde Strickler Chronister, Store Manager, 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 October 2, 2013 to Sondra Reed at 250 Cloverlane Drive, Manchester; PA 17345. 05/13/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $89.26 SO ANSWERS, May 13, 2014 (c) CounlySuite Sheriff, Teleosoft. Inc. RONRR ANDERSON, SHERIFF