HomeMy WebLinkAbout11-9284SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FIL.EO-O FIC :
Sheriff OF THE PROTHONOTARY
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Jody S Smith
Chief Deputy 7011 OEC 29 AM 8: 32
Richard W Stewart CUMBERLAND COUNTY
Solicitor
PENNSYLVANIA
LVNV Funding, LLC Case Number
vs. 2011-9284
Sheila A. Byers
SHERIFF'S RETURN OF SERVICE
12/19/2011 06:59 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on
December 19, 2011 at 1859 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Sheila A. Byers, by making known unto herself personally, at 1275
Baltimore Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same
time handing to her personally the said true and correct copy of the same.
L BARRIC , DE UTY
SHERIFF COST: $48.00
December 20, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
rc: Couni,Suite Shenff. Teloosoft, Inc
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA f +-
LVNV FUNDING LLC
Plaintiff
vs.
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Defendant
CIVIL DIVISION ' ''" }. 'f' --- r! I I t;
NO: 11-9284
NO COUNT'%(
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 $14,731.71. 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. A
ichkl F. R*chford, Esquire
ttorney I.D. No.: 86285 am? 01b st)pd
AAAtttorney for Plaintiff
? ?2# a-73s11 -mod
JUDGMENT ?0h a
AND NOW, this ok day of i 11 20 I,.7 Judgment is hereby entered in favor
of the Plaintiff, LVNV FUNDING LLC and against the Defendant, Sheila A Byers in the amount
of $14,731.71 for failure to respond to Plaintiff's Complaint.
PROTHONOTAR
J.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
Plaintiff
vs.
Sheila A Byers ,
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Defendant
CIVIL DIVISION
NO: 11-9284
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:
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Date: April 2, 2012
Edwin A. Abrahamsen & Associates, P.C.
By: !/' I
M' ael . Ratchford, Esquire
orney I.D. No.: 86285
120 N. Keyser Avenue
Scranton, PA 18504 /
(570) 558-5510 l
LVNV FUNDING LLC
Plaintiff
vs.
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Defendant
In the Court of Common Pleas of
CUMBERLAND County, Pennsylvania
Civil Division
NO: 11-9284
NOTICE OF FILING JUDGMENT
Notice is hereby given that a money judgment in the above-captioned matter has een entered
against you in the amount of $? [- , 7 31.7 ? on a-
Ver.,s
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)
LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County, Pennsylvania
Civil Division
vs.
NO: 11-9284
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSB[JRG PA 17257-9422 AFFIDAVIT UNDER SOLDIERS AND SAILORS
RELIEF CIVIL RELIEF ACT OF 1940 AS
Defendant AMENDED
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): Sheila A Byers 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): Sheila A Byers is(are) older than eighteen years of age;
That the employment status of the defendant(s): Sheila A Byers is(are) unknown.
Subscribed before me this _ , day of ???a R_ 20 it
? P.
Notary Public
COMMONWEALTH OF PEAMISSYWM1iA
Notarial Seal
Midwei C. Sowa, Notary Pubk
Plains Twp., uuzeme County
My CommWw Expires Jan. 24, 2014
Member, Pennsylvania Association of NotarieS
EYWIN A. ABRAHAMSEN
MICHAEL F. RATCHFORD
*MN J. CLIMMINCS THE LAW OFFICE OF
NINA MENICHEW EM0N ?.ABR-kF Al%F'UN F 3 ';GGUTBti, PC
WWW.EAA.t_Aw.c6r.1
January 30, 2012
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBUR.G PA 17257-9422
Re: LVNV FUNDING LLC v. Sheila A Byers
CUMBERLAND County Civil Action No.: 11-9284
Our file No.: RI 107899/JMB
Dear Sheila A Byers:
Enclosed please find 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 & Associates,
117 ?
,All 1z
Kevin J. Cummings, Esquire
Enclosure
This is a communication from a debt collector in an attempt to collect a debt. Any inforination
will be used for that purpose.
120 N KEYSER AYE SCRANTON, PA 18504 (P) 570.558.5510 (F) 570.558.5511
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV FUNDING LLC
CIVIL ACTION
Plaintiff :
Vs.
: NO: 11-9284
Sheila A Byers
Defendant
TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
To: Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Date of Notice: January 30.2012
IMPORTANT NOTICE PURSUANT TO PA.R.C.P. 237.I(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 FOWL-H 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
LVNV FUNDING LLC
CIVIL ACTION
Plaintiff
vs.
NO: 11-9284
Sheila A Byers
Defendant
CERIFICATE OF SERVICE
1. 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:
Sheila A Byers
1275 BALTIMORE RD
SHIPPENSBURG PA 17257-9422
Edwin A. Abrahamsen & Associates, P.C.
BY
Mic ae F. atchford, Ilqre
Attorney I.D. No.: 86285
Kevin J. Cummings, Esquire
Attorney I.D. No.: 209660
120 N Keyser Avenue
Scranton, PA 18504
(570) 558-5510
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 05:36:13
< Last Service
S
Name First/Middle Begin Date Active Duty Status Active Duty End Date Agency_
BYERS SHEILA A Based on the information you have furnished, the DMDC does not 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).
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 2,2209-2593
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 http://www.defenselink.mil/fag/i)is/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 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 IDAGPSG8IA09
https://www.dmdc.osd.mil/appj/scra/popreport.do 4/2/2012