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Home My WebLink About11-4288SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE (1?-7 THE PRQTHC?NOTt?#?'' 4pip ct ?ambrr??? It' Jody S Smith ? 20! I MAY 27 AM 9: 48 Chief Deputy ???, Richard W Stewart solicitor ` F' `' "`?`'FF UM?BIwRL?1?dD ENNSYLVANIA Ford Motor Credit Company Case Number vs. 2011-4288 Matthew Wells-Thomas SHERIFF'S RETURN OF SERVICE 05/18/2011 09:06 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 18, 2011 at 2106 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Matthew Wells-Thomas, by making known unto Adrienne Wells-Thomas, Wife of Defendant at 169 E. South Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $34.00 May 19, 2011 SO ANSWERS, o ? ?? P? ? .. RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft, Inc. 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 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT COMMON PLEAS CASE NO. 11-4288 CIVIL L ? ? C7 "n v n =c X-;=; 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, MATTHEW WELLS-THOMAS in the amount as follows: Principal Amount $ 7979.76 Interest to Date $ 108.35 Costs $ 126.00 TOTAL $ 8214.11 Date: June 22, 2011 .M+%1q.b0pd 0h 01, ?? S&'7 ox 333 Nat-.?C' (W le d JOANN NEEDLEMAN, ESQ. Attorney 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. 15535 (2 1J) /z5y-/IDI FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 CIVIL (X) Notice is hereby given that a judgment in the above-captioned matter has been entered against you in the amount of $8214.11 on s (X) A copy of all documents filed with the Prothonotary in support of the within judgment is enclosed. N ft'%' 0!% n 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) i `?k ?: > ' Wy ???; 9 .? ?y w ? 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?) /69-/IDI FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 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 06/10/2010 she mailed a written Notice of Intention to File the Praecipe to Defendant, MATTHEW WELLS-THOMAS , at 169 E SOUTH ST , CARLISLE, PA 17013-3429 by regular mail. MAURICE &/1 aDLEMAN, P.C. SWORN TO AND SUBSCRIBED before me thisay of , 201 ? ?J?Notary Public BY: JOAN NEEDLEMAN, ESQ. Attorney for Plaintiff NOTARIAL SEAL RASHETTA ROBINSON Notary Public PHILADELPHIA CITY. PHILADELPHIA COUNTY My Commission Expires Mar 23. 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 1J) /69-/151 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY' Plaintiff V. MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 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 06/10/2010 to Defendant, MATTHEW WELLS-THOMAS , 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 06/10/2010, a copy of the mailing to the Defendant and affidavits of service are all attached hereto. MAURICE & DLEMAN, P.C. BY: , R ANN Attorney for Plaintiff Date: June 22, 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 (L1J) /tSy-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff v. MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 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: MATTHEW WELLS-THOMAS, 169 E SOUTH ST, CARLISLE, PA 17013-3429 MAURIC & N LEMAN, P.C. BY: JOANN NEEDLE AIV,--EqAttorney for Plaintiff Date: June 22, 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 (21J) /ZSV-/1J1 FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. MATTHEW WELLS-THOMAS Defendant(s) CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 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, MATTHEW WELLS-THOMAS , 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. MAURIC & LEMAN, P.C. BY: JOANN NEEDLEMAN, ESQ. Attorney for Plaintiff SWORN TO AND SUBSCRIBED bef e in this day vim201' 4- , NOTARIAL SEAL RASHETTA ROBINSON otary Public Notary Public PHILADELPHIA CITY. PHILADELPHIA COUNTY My Commission Expires Mar 23, 2015 June 10, 2011 Our File No. 15535 Attorneys at Law uite 935, One Penn Center 317 John F. Kennedy Blvd. Phitadeohia, PA 19103 tel. 215.665.1133 fax 215.563.8970 www.mnlawpc.com Donald S. Maurice Member NJ Bar Board Certified Creditors' Rights Law mean Board of Certi icatron Joann Needleman Member PA & NJ Bar Thomas R. Dominczyrk Member NJ. NY & PA Bar Rachel Marin Member NY & NJ Bars New Jersey Office Maurice & Needleman, P,C Suite 20O 5 Walter E. Foran Blvd Flemington, NJ OB82i tel. 908.237.455( tax 908.237.455' MATTHEW WELLS-THOMAS 169 E SOUTH ST CARLISLE, PA. 17013-3429 RE: FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY v. MATTHEW WELLS-THOMAS CUMBERLAND COUNTY COURT OF COMMON PLEAS, CASE NO. 114288 CIVIL Dear Mr/Mrs/Ms WELLS-THOMAS: 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 May 18, 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. Joa eedleman, 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 93 One Penn Center 1617 John F. Kennedy Blvd Philadelphia. PA 19103 Attorneys for Plaintiff /2Sy- / t JJ FORD MOTOR CREDIT COMPANY, A DELAWARE LIMITED LIABILITY COMPANY Plaintiff V. MATTHEW WELLS-THOIvLkS CUMBERLAND COUNTY COURT OF COMMON PLEAS CASE NO. 11-4288 CIVIL IMPORTANT NOTICE TO: MATTHEW WELLS-THOMAS DATE: June 10, 2011 169 E SOUTH ST CARLISLE, PA 17013-3429 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 Libertv Avenue, Carlisle, PA 17013 (717)249-3166 MAURICE "EEDLEMAN, P.C. A BY JOANN NEE, MAN, ESQUIRE Attorney for PP intiff 062$0005583191 ?z 401 U) co 14 cc>,r ,q 0) N OyVio E 48.0 z CL 0 - d i- W O) OWN HUZM W Z 'sU)m ?- W LU co ?w? c U z w w ho °z Z w UCL CZQ Z W W EL TfZQ O? <rnCL SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OPME GF TFtc &` QRirF D? Z6 Ford Motor Credit Company Case Number vs. 2011-4288 Matthew Wells-Thomas SHERIFF'S- RETURN 05/18/2011 09:06 PM - Noah Cline, Deputy Sheriff, who being duly swum according to law, states that on May 18, 2011 at 2106 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Matthew Wells-Thomas, by making known unto Adrienne Wells-Thomas, Wife of Defendant at 169 E. South Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $34.00 May 19, 2011 (G;• l.Oiv,6.46 Sherd. de s", Inc. SO ANSWERS, 6z ?? RON R ANDERSON, SHERIFF Request for Military Status Department of Defense Manpower Data Center r Military Status Report ' Pursuant to the Service Members Civil Relief Act n" II? ?- ?r G Mar-30-2011 11:27:07 Service Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Agency WELLS- MATTHEW Based on the information you have furnished, the DMDC does not THOMAS 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). y6t /it. DW?_ 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 littLi:/,,www.defenselink.mil/faci/pis/PC09SLDR.litnil. 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. https://www.dm&.osd.mil/appj/scra/popreport.do 3/30/2011 . Request for Military Status Page 2 of 2 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 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:MRT6BQBV24 https://www.dmdc.osd.mil/appj/scra/popreport.do 3/30/2011