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Home My WebLink About11-6216JL r iCE ! rjlu! v t r i 2: lI S " . MBERLA!- 0 C0U"IV PENNSY `,'ANIA PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service MUST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AFFIDAVIT: I hereby (swear) (affirm) that I served ss ® a copy of the Notice of Appeal, Common Pleas No. 11-6216 CIVIL, upon the Magisterial District Judge designated therein on (date of service) 8/16, 2011, ? by personal service ® by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) MICHAEL A. HOLMES, on 8/16,2011 ?by personal service- ® by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS 16TH DAY OF AU 2011 ?,,Si re of official before whom affidavit was made Title of official My commission expires on APRIL 2, 2014 Signature of affiant -yd VWW-4'j AOPC 312A - 05 r u ro m M rU O O O O M ra 0 r- ii f I I' wNIiidf11?'¦i l????fii?I?IIN1 ( F'I F'o .tr ir''c fie' 11 'H hLl_ A. HOLMES I W ;R IELI) RD ?` ?II I I L, PA 17011 ................ Af III AYRr YYYAL IrN lM? 1??l?? ?? r. 7 1( I CO '? f?l II ??Ir ??I14?... I • i1 '?' I.•I .? . !,?Y tilfIll?rY/Et 9T ?'YI pII ` -!I m I O - -----I Postmark O ipt F' Here O ''m erI f w rra O ?.---- i teJ Ucln ry Fc , r EISTRICT COURI'09-1-01 O f CLDE TOWNE; COMMON'S o I 4)0 BRIDGE: ST. SUITE 3 I 1` EW CUMBERLAND, PA 17070 ................. IN THE COURT OF COMMON PLEAS OF rt: r'!_ CUMBERLAND COUNTY, PENNSYLVANIA ?- ; - ?..JE it ... ?J1??0 N$ ADVANTAGE ASSETS II, INC. CIVIL DIVISION Plaintiff vs. MICHAEL A HOLMES 84 DEERFIELD RD : NO: 11-6216 CIVIL CAMP HILL PA 17011-8469 Defendant C3 10 CWNT Y u.f +S,rEwAl .\ PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE CLERK OF JUDICIAL RECORDS: Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the amount of $9,672.43. Notice of the intent to file a default judgment was served upon the Defendant on October 11, 2011. A copy of the Notice of Intent to Take Default Judgment is attached hereto and marked Exhibit "A." A. Abrahamsen & Michael K-Ratchford, Esquire / Attorney I.D. No.: 86285 Attorney for Plaintiff am% ly oolzId Q? JUDGMENT cp(64N S AND NOW this v06\hi } WN day of , 20k, Judgment is hereby entered in favor of the Plaintiff, ADVANTAGE ASSETS II, INC. and against the Defendant, MICHAEL A HOLMES in the amount of $9,672.43 for failure to respond to Plaintiff's Complaint. PROTHONOTAR J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADVANTAGE ASSETS II, INC. Plaintiff : CIVIL DIVISION VS. NO: 11-6216 CIVIL MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 Defendant , CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served a 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: MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 Date: November 25, 2011 Michael F. Ratchford, Esquire Attorney I.D. No.: 86285 120 N. Keyser Avenue Scranton, PA 18504 (570) 558-5510 Edwin A. Abrahamsen & Associates, P.C. ADVANTAGE ASSETS II, INC. vs. In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 NO: 11-6216 CIVIL Defendant . NOTICE OF FILING JUDGMENT Notice is hereby given that a money judgment in the above-captioned matter has been entered against you in the amount of $ SLO a,1f 3 on r By: ML 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) ADVANTAGE ASSETS II, INC. In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division vs. NO: 11-6216 CIVIL MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Defendant State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): MICHAEL A HOLMES is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): MICHAEL A HOLMES is(are) older than eighteen years of age; That the employment status of the defendant(s): MICHAEL A HOLMES is(are) unknown. Subscribed before me this ay o ? 0 otary Public SCRANW, i LACKS,' My Commission Expires EDWIN A ABRAHAMSEN WOOL F. RATCHFORD MVIN J. CUMMINCS NINA MENICHEW iffy THE LAW OFFICE OF BE?lMIN i.-iEPkILA 11Li-IM .; _i, '14.` :TFL`. F+` WWW.EAA-LAWX (00 October 11, 2011 MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 Re: ADVANTAGE ASSETS II, INC. v. MICHAEL A HOLMES CU11BERLAND County Civil Action No.: 11-6216 CIVIL Our file No.: TI 100888/PJR Dear MICHAEL A HOLMES: Enclosed please find the Ten Day Notice of Intent to "fake 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 & Associates, • L Kevin J. mmings, Esquire 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 N KEYSER AYE MANION, PA 18504 (P) 570.558.5510 (F) 570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADVANTAGE ASSETS II, INC. CIVIL ACTION Plaintiff VS. MICHAEL A HOLMES NO: I 1-6216 CIVIL Defendant : TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 Date of Notice: October 11, 2011 IMPORTANT NOTICE PURSUANT TO PA.R.C.P. 237.1(a)(2) 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 [-TEARING 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. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ADVANTAGE ASSETS 11, INC. Plaintiff vs. MICHAEL A HOLMES CIVIL ACTION NO: 11-6216 CIVIL Defendant CERIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on October 11, 2011 1 served a 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: MICHAEL A HOLMES 84 DEERFIELD RD CAMP HILL PA 17011-8469 Edwin A. Abrahamsen & Associates, P.C. BY: Michae •. R tchford, Esquire Attorney I.D. No.: 86285 Kevin J. Cummings, Esquire Attorney I.D. No.: 209660 120 N Keyser Avenue Scranton. PA 18504 (570) 558-5510 •_equest for jViiitary Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Nov-14-2011 06:14:47 < Last First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Name MICHAEL A Based on the information you have furnished, the DMDC does not possess HOLMES 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, 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 httu•//www.defenselink.mil/fagpis/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. 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.dmdc.osd.mil/appj/scra/popreport.do 11/14/2011 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:7QGHPUMFFN https://www.dmdc.osd.mil/appj/scra/popreport.do 11/14/2011