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Home My WebLink About11-9202. FL FILL THE F' ° HON0TW* 2011 DEC 21, PM 3-* 05 CUpEN?NsyVCOUNTY t?A +A 11El1"I 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 ; ss AFFIDAVIT: I hereby (swear) (affirm) that I served ® a copy of the Notice of Appeal, Common Pleas No.11-9202, upon the Magisterial District Judge designated therein on (date of service) 12/21, 2011, ? by personal service ® by (certified) (registered) mail, sender's receipt attached hereto, and upon the appellee, (name) TRINA GARCIA, on 12/21,2011 ?by personal service_ ® by (certified) (registered) mail, sender's receipt attached hereto. (SWORN) (AFFIRMED) AND SUBSCRIBED BEFORE ME THIS 21ST DAY OF DECEMBER, 2011 was made Notrfrl l SW Dye E, Rupp. CrotrKy Publk County d ' 20.2015 Title of official My commission expires on l ZU 20 AOPC 312A - 05 tj.?. Postal Service U.S. Postal Service CERTIFIED MAIL, RECEIPT GgRTIFIED o M (Domestic Mail Only; No Insurance Coverage Provided) m ?. mail only, No Insurance Coverage provided) M For delivery information visit our website at www.us M m o 0 Postaete $_..,._? r- 70stage ? N Certified (-ee Certilled Fee N .. Postmark f1J C3 Return Receipt Fee -- Here Ca Return Receipt Fee Postmark C3 (Endorsement Required) - C] (Endorsement Required) Here C3 Restricted Delivery Pee C3 Restricted Delivery Fee -° - ?` (ER fo sement Required) CJ (Endorsem^-' co Total P DISTRICT COURT 09-3-03 ? Total Pc TRINA A GARCIA nt 70 229 MILL STREET o"` ° 6,5 SUNNYSIDE DR MOUNT HOLLY SPRINGS PA ---- 0 3`fretet,AE CARLISLE PA 17015 C3 ------ A or PO Bo 0 street. or PO a ??- 17065 __ City Stats, ------ City, Ste IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK (USA), N.A. MW CIVIL ACTION =u S Plaintiff )r- -< 1 .1 1 c ,. 2: z cz? vs. 5;c:: ;-; -- TRINA M GARCIA NO: 11-9202 Defendant CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on December 27, 2011 the below named District Justice received and signed for the certified mail containing the Plaintiff s Notice of Appeal of the District Justice Judgment. District Court 09-3-03 229 Mill St. PO Box 167 Mount Holly Springs, PA 17065 Edwin A. Ajrhamsen & Associates, P.C. Michael F. Ratchford, Esquire Attorney I.D. No.: 86285 120 N Keyser Avenue Scranton, PA 18504 (570) 558-5510 SENDER. u Complete items 1, 2, and 3. Also complete A.' item 4 if Restricted Delivery Is desired. X Afire • Print your name and address on the reverse 13 so that we can return the card to you. g, iv (Printed Name) C. Date Del ¦ Attach this card to the back of the mailpiece,? it or on the front if space permits. _ D. Is delivery dress different from item 1? 9?('Ye 1. Article Addressed to: If YES, $n r delivery address below: X No N011 C9 1 ? DISTRICT COURT 09-3-03 229 MILL STREET MOUNT HOLLY SPRINGS PA 17065 3. SeDrIce Type Certified Mail ? Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured mail 0 C.O.D. 4. Restricted Delivery? (Btra Fee) 0 Yes 2. Article Number 7010 1870 0002 4700 3943 (Transfer from service (abet) Ps Form 3811, February 2004 Domestic Return Receipt n8"1540 ¦ Complete items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can retum the card to you. ¦ Attach this card to the back of the maiipiece, or on the front if space permits. A. X 0 Agent 1. Article Addressed to: 1-7 TRINA A GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015 g.teeiverNby (Printed Name) I c. Date of Delivery D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No r ? n 3. sw*e Too I§ZwUW Mail a Express Mall ? Reghtmed 0 Return Receipt for Merchanalae (3 lrwnw mall 0 c o.D. 4. Restricted Deliverffikha Fee) 0 Yes 2. MicleNumber 7010 1870 0002 4700 3936 (warms from servike label) PS Form 3811, February 2004 Domestic Return Receipt 10259 42-x+ I540 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK (USA), N.A. CIVIL ACTION vs. TRINA M GARCIA Plaintiff NO: 11-9202 Defendant a <C:1 -+ ? C-- a 77 -tee' CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on December 24, 2011 the below named Defendant received and signed for the certified mail containing the Plaintiff's Notice of Appeal of the District Justice Judgment and Complaint. TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK (USA), N.A. CIVIL DIVISION Plaintiff vs. TRINA M GARCIA 65 SUNNYSIDE DR ; NO: 11-9202 CARLISLE PA 17015-9038 Defendant PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE CLERK OF JUDICIAL RECORDS: ' C?1C i ii%u -k ri 'EHJ'4SYLVANIA Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the amount of $1,437.70. Notice of the intent to file a default judgment was served upon the Defendant on January 30, 2012. A copy of the Notice of Intent to Take Default Judgment is attached hereto and marked Exhibit "A." Edwin A. Ab ahamsen & 414z Mich 1 F. Ratchford, Es Attorney I.D. No.: 8628 Attorney for Plaintiff JUDGMENT aro,-4 14.SDpaH, C c 1:513 7 0 tea, 3IS6 le AND NOW, this day of Avv i 2012, Judgment is hereby entered in favor of the Plaintiff, CAPITAL ONE BANK (USA), N.A. and against the Defendant, TRINA M GARCIA in the amount of $1,437.70 for failure to respond to Plaintiff's Complaint. SOM PROTHONOTA .. J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL ONE BANK (USA), N.A. Plaintiff vs. TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 Defendant CIVIL DIVISION NO: 11-9202 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: TRINA M G.ARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 Date: April 2, 2012 Edwin A. Abrahamsen & Associates, P.C. r-.7 - Michael f Ratchford, Esqui Attorney I.D. No.: 86285 120 N. Keyser Avenue Scranton, PA 18504 (570) 558-5510 CAPITAL ONE BANK (USA), N.A. In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division VS. TR1NA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 NO: 11-9202 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 $ 1,? ( 3 7. C' on ?} q 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) CAPITAL ONE BANK (USA), N.A. Plaintiff vs. TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 Defendant State of Pennsylvania County of CUMBERLAND SS: In the Court of Common Pleas of CUMBERLAND County, Pennsylvania Civil Division NO: 11-9202 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS AMENDED Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): TRINA M GARCIA 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): TRINA M GARCIA is(are) older than eighteen years of age; That the employment status of the defendant(s): TRINA M GARCIA is(are) unknown. Subscribed before me th' day o \ 20 Notary Publ' EDWIN 0. ABRAIIAMSEN MICHAEL F. RAXH FORD KEVIN J. CUMMINGS NINA MENICHELIJ ¦ i i1 THE LAW OFFICE OF HDlt7NA.ABIRUMNSEN C.S?OCLVTg .PC WWW.EAA•LAW.COM .January 30, 2012 TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 Re: CAPITAL ONE BANK (USA), N.A. v. TRINA M GARCIA CUMBERLAND County Civil Action No..- 11-9202 Our File No.: NA113717/AFS Dear TRINA M GARCIA: Enclosed please find the Ten Day Notice of Intent to 'l'ake 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, I/ ?-?7 Kevin J. Cummings, 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 KEYS11 AYf SCRANTON, PA 18504 (P) 570.558.5510 (1) 510.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL, ONE BANK (USA), N.A. : CIVIL ACTION Plaintiff : vs. TRINA M GARCIA : NO: 11-9202 Defendant : TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE PA 17015-9038 Date of Notice: January 30- 2012 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 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. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CAPITAL, ONE BANK (USA), N.A. : CIVIL ACTION Plaintiff vs. TRINA M GARCIA NO: 11-9202 Defendant CERIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on January 30, 2012 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: TRINA M GARCIA 65 SUNNYSIDE DR CARLISLE; PA 17015-9038 Edwin A. Abrahamsen & Associates, P.C. y 85 Kevin J. Cummings, Esquire Attorney I.D. No.: 209660 120 N Keyser Avenue Scranton, PA 18504 (570) 558-5510 BY: Michael atc.: hford, 862Esquire Atiorne1. .No Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Apr-02-2012 11:57:53 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency Based on the information you have furnished, the DMDC does not possess GARCIA TR INA M 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). 14 % nktut In. A?M_ 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 httn://www.defenselink.mil/fact/nis/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 4/2/2012 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 RDAs. 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:IJ72FU2BH2 https://www.dmdc.osd.mil/appj/scra/popreport.do 4/2/2012