Loading...
HomeMy WebLinkAbout11-8967F TILES\Cllems\7619 Dickinson College\7619.Collections\7619.C.Current\398 Zuckerman\7619C.398.pra. reinstate Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff PEl???Y?-???1 A DICKINSON COLLEGE, Plaintiff V. DAVID M. ZUCKERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 8967 : CIVIL ACTION - LAW PRAECIPE To the Prothonotary: Please reinstate the Complaint in the above-referenced matter. MARTSON LAW OFFICES By: aL Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: Attorneys for Plaintiff THIS IS A DEBT COLLECTING FIRM ATTEMPTING TO COLLECT A DEBT FOR DICKINSON COLLEGE. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. a?9,09 F TILES\Clients\7619 Dickinson College\7619.Collections\7619.C-Current\398 Zuckerman\7619C.398.as Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. DAVID M. ZUCKERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 8967 : CIVIL ACTION - LAW AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. _o rr; r--1 a~4? N •?.d r.,a 7, 7 I hereby certify that a copy of the Complaint in the above captioned matter was mailed to David M. Zuckerman, 1060 Dean Street, Schenectady, NY 12309-5720, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed by David Zuckerman, and dated March 3, 2012, with attached receipt of costs in the amount of $10.50. MARTSON LAW OFFICES y Christopher E. Rice, Esquire Attorney I.D. No. 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Sworn to and subscribed before me this d 1d)- day of March, 2012. 1i No a ublic apMM0NWE41.1Y1 OF PENNSYLVANIA Notarial Seat Mary M. Price, Notary Public CwWe emo, cumberiand 18 emrlowBq*es Aug. 2015 VANIA 7ION OF NOTARIES ¦ Cwnpiea lams 1, 2, and 3. Also complete lam 4 If Restricted Delkwy is desired. ¦ Print your rwne and address on the reverse so that we can mWm the card to you. ¦ Attach this card to the back of the mailpiece, or on the front N space permits. 1. Article Addressed to: 4,0 ?y S A. Sliggahm X 13 Agent ? Ad*mm B. Rebl eel( Irft,W Nam) C. Date Ddyery l of D. Is delivery address dfflerent from Item 11 O Yes If YES, enter ddvery address below: ? No 3. Service IW* Mail ? Express Mall Registered O Pakinr Rwelpt for Momhwxbe 0 bmjmd man p cza 4. Rn*bW D7dMwyt Oft F" 2. ArtldeNumber 7011 2000 0001" 2522 5158 %aw (1lanrrlirhamaerwits PS Form 3811, February 2w Domestio Return Reoeipt 102MG-02-WI540 CC) i-n Ln ru L ru u1 Postage ti Certified Fee M Retum Receipt Fee a (Endorsement Required) 0 Restricted Delivery Fee C3 (Endorsement Required) O C3 Total Postage & Fees ru r-q r-q O ('I- Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011 - 8967 DAVID M. ZUCKERMAN, CIVIL ACTION - LAW Defendant TO: DAVID M. ZUCKERMAN, DEFENDANT NOTICE OF ENTRY OF DEFAULT JUDGMENT ?t You are hereby notified that on the X.5 I day of T. , 2012, the following Judgment was entered against you in the above-captioned action: judgment in the amount of $15,406.48, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $3,000.00, and costs of suit. Date: ?I ;2- Prothonotary I hereby certify that the name and address of the proper person to receive this notice under Pa. R. Civ. P. 236 is: David M. Zuckerman 1060 Dean Street Schenectady, NY 12309-5720 F.\FILES\Clients\7619 Dickinson College\7619. Collections\7619.C.Current\398 Zuckerman\7619C.398.pra default ci) -' Christopher E. Rice, Esquire Attorney I.D. No. 90916 mM 0 -13 r- MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER f-- N 70 MARTSON LAW OFFICES rn C) Ten East High Street ' - Carlisle, PA 17013 (717) 243-3341 " Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYL VANIA V. NO. 2011 - 8967 DAVID M. ZUCKERMAN, CIVIL ACTION - LAW Defendant PRAECIPE TO THE PROTHONOTARY: Enter default judgment in the above-captioned action in favor of Plaintiff and against Defendant in the of amount of $15,406.48, plus interest accruing at 5% per annum, collection and attorneys' fees in the amount of $3,000.00, and costs of suit as prayed for in the Complaint, for failure to file an Answer to Plaintiffs Complaint. I do hereby certify that a written notice of intention to file this Praecipe was mailed to the Defendant at the address indicated thereon, on March 26, 201, which date was subsequent to the date default occurred and at least ten (10) days prior to the date of the Praecipe. MARTSON LAW OFFICES By Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Dated: Ala S / ' P i lv 4 J6 C ",Lovd F--.\FILES\Clients\7619 Dickinson College\7619.Collections\7619, C.Current\398 Zuckerman\7619C. 398.10daynotice Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2011 - 8967 DAVID M. ZUCKERMAN, CIVIL ACTION - LAW Defendant IMPORTANT NOTICE TO: David M. Zuckerman Date: March 26, 2012 1060 Dean Street, Schenectady, NY 12309-5720 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITTEN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT 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. This a debt collecting firm attempting to collect a debt for Dickinson College Any information obtained will be used for that purpose. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 By: MARTSON LAW OFFICES f? ` 7 Christopher E. Rice, Esquire Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. DAVID M. ZUCKERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 8967 : CIVIL ACTION - LAW AFFIDAVIT AS TO MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA ) :SS. COUNTY OF CUMBERLAND Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he has authority to make this affidavit on behalf of his client, and to the best of his knowledge, information and belief, the Defendant above named is not in the military service of the United States of America, that he has knowledge that the said Defendant is now living at: 1060 Dean Street, Schenectady, NY 12309-5720. Said Defendant's place of employment is unknown. Christopher E. Rice, Esquire Sworn to d subscrib d before me this Sday of , 2012 (e No a ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public C.arlWe Sato, Cumberland County CONMl won E2ires A . 18, 2015 ASRO?TA71AN of NOTARIES Department of Defense Manpower Data Center Results as of: Apr-24-2012 12:27:04 Status Report Pursuant to the Sercicemember= CiVil Relief Act Last Name: Zuckerman First Name: Date Of Interest: Apr-2472012 Active Duty End Date Status Service Component On Active Duty On Date of Interest No NA This response reflects the individual's active duty status based on the Date of Interest. Left Active Duty Within 367 Days of Date Of Interest No NA This response reflects whether the individual left active duty status within 367 days preceding the Date of Interest. The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Date of Interest No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the date of interest as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. y6t yl,. Mary M. Snavely-Dixon, Director Department 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 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 date of interest, 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 date of interest 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., a SSN, First Name), you can submit your request again at this Web site and we will provide a new certificate for that query This response reflects the following information: (1) The individual's Active Duty status on the Date of Interest (2) Whether the individual left Active Duty status within 367 days preceding the Date of Interest (3) Whether the individual or his/her unit received early notification to report for active duty on the Date of Interest. 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 (NOAH 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, and date of interest provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: null Christopher E. Rice, Esquire Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff DICKINSON COLLEGE, Plaintiff V. DAVID M. ZUCKERMAN, Defendant COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2011 - 8967 CIVIL ACTION - LAW : SS Christopher E. Rice, Esquire, being duly sworn according to law, deposes and says that he is an employee of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, attorneys for the Plaintiff in the above captioned matter and that pursuant to the provisions of the Pennsylvania Rules of Civil Procedure, a notice of intention to enter default judgment against the Defendant was given to him by mail on March 26, 2012. /C. _ Christopher E. Rice, Esquire Sworn to and subscr bed rI before me this day of 92012. LA, lltQJ N0,47 /public COMMONWEALTH OF PENNSYLVANIA Notarial seal Mary M. Price, Notary Public Carlisle 8oro, Cumberland County My Comnds on Expires Aug. 18, 2015 MEMBER, PENNSYLVANIA ASSOCIATON OF NOTARIES CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: David M. Zuckerman 1060 Dean Street Schenectady, NY 12309-5720 MARTSON LAW OFFICES Y Many Price Ten East High Street Carlisle, PA 17013 (717) 243-3341 Dated:' This is a debt collecting firm attempting to collect a debt for Dickinson College. Any information obtained will be used for that purpose