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Home My WebLink About12-4960IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF Consumer Acquisition 15 South Main Street Greenville, SC 29601 CIVIL ACTION Plaintiff vs. Randall L Meagher 229 Walton St Lemoyne PA 17043-2025 Defendant : LE--D--0FFK ' :I)ROTHONOTAF0 .fl? -9 P11 1: 47 5JLf\LAND COUNTY PENNSYLVANIA NO: I a - (?g(fi6 60 ( NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice to Defend are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 CJ aIm 1 -S Io3. 7Sfd a Ck'ff y9y// PJ a'19 090 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF Consumer Acquisition 15 South Main Street CIVIL ACTION Greenville, SC 29601 Plaintiff vs. Randall L Meagher NO: 229 Walton St Lemoyne PA 17043-2025 Defendant Nr: XX I......L' ?L: t•. r COMPLAINT Plaintiff, CVF Consumer Acquisition, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, CVF Consumer Acquisition, (hereinafter "Plaintiff") is a Delaware corporation with a principal place of business located at 15 South Main Street Greenville, SC 29601. 2. The Defendant Randall L Meagher (hereinafter "Defendant") is an adult individual residing at 229 Walton St Lemoyne PA 17043-2025. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by MBNA with the account number ending in 4712. 5. The within account was sold by MBNA to CVF Consumer Acquisition for valuable consideration and all rights under said accounts were assigned to CVF Consumer Acquisition. 6. Use of the MBNA credit card was subject to the terms and conditions of the Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent along to the Defendant with the credit card. A copy of this document has been requested from MBNA, and will be provided upon receipt. 7. Defendant used the MBNA credit card with account number ending in 4712, for purchases, cash advances and/or balance transfers. Use of the card in this manner constituted acceptance of the terms and conditions and subjects the Defendant to the terns and conditions contained therein. The Defendant was mailed monthly account statements relative to the Defendant's use of the subject credit card. 9. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 10. The Defendant last made payment on December 28, 2009. 11. The principal amount was $14,232.84 at the time of charge-off. 12. Pursuant to the account agreement, any unpaid balance accrues interest. 13. The total amount due and owing the Plaintiff including interest, is $14,232.84. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $14,232.84 plus costs of suit and any other relief as the Court deems just and appropriate. Re nter?& Assoc. Michael F. Ratch rd(Esquire Attorney LD. No .: 86285 120 North Keys r Ave. Scranton, PA 1 504 mratchford@e -law.com Phone: 570-5 8-5510 Fax: 570-558-5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff,CVF CONSUMER ACQUISITION COMPA, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF CONSUMER ACQUISITION COMPANY CIVIL DIVISION - Plaintiff T' vs. -< c a Randall Meagher NO. 12-4960 J ry `? 229 Walton St Lemoyne PA 17043-2025 Defendant 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 $14,207.84. Notice of the intent to file a default judgment was served upon the Defendant on October 15, 2012. A copy of the Notice of Intent to Take Default Judgment is attached hereto and marked Exhibit "A." A. Abrahamsep & Michael F. Ratchford, Attorney I.D. No.: 862 Attorney for Plaintiff/ JUDGMENT AND NOW, this - day of Jan , 2013, Judgment is hereby entered in favor of the Plaintiff, CVF CONSUMER ACQUISITION COMPANY and against the Defendant, Randall Meagher in the amount of $14,207.84 for failure to respond to Plaintiff's Complaint. PROTHON R "% J. -* I !o • 50 P o ATT%-/ C# 550x5 e a8.6'7 4 9 Oia' Walled EDWIN k ABRAHAMSEN MICHAEL F. RATCHFORD NINA MENICHEW THE LAW OFFICE OF t31)l[7W a._-1,BR tL-khtS9N &-A SSGCLATSS. PC WWW.FAA-LAW.C0 October 16, 2012 Randall Meagher 229 Walton St Lemoyne PA 17043-2025 Re: CVF CONSUMER ACQUISITION COMPANY v. Randall Meagher CUMBERLAND County Civil Action Afo_ -12- 1960 Our file No.: R 1205633/LS Dear Randall Meagher: 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 & Associat Mich el F. Enclosure This is a communication from a debt collector in an will be used for that purpose. Esquire to collect a debt. Any information 120 N KEYSER AVE 5{RANTON, PA 18504 (P) 570.558.5510 (F) 570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF CONSUMER ACQUISITION COMPANY : CIVIL ACTION Plaintiff : vs. NO: 12-4960 Randall Meagher Defendant : TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: Randall Meagher 229 Walton St Lemoyne PA 17043-2025 Date of Notice: October 16, 2012 IMPORTANT NOTICE PURSUANT TO PA.R.C N 237 1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN A'T'TORNEY 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 T14AT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE- MIDPENN LEGAL SERVICES 401 FAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF CONSUMER ACQUISITION COMPANY Plaintiff vs. Randall Meagher Defendant CIVIL ACTION NO: 12-4960 CERIFICATE OF SERVICE I, Michael F. Ratchford, Esquire; hereby certify that on October 16, 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: Randall Meagher 229 Walton St Lemoyne PA 17043-2025 Edwin A. Abrahamsen & Associates, P.C. !BY: V " Michael F. Ratchford, Es ui Attorney I.D. No.: 86285 120 N Keyser Avenue Scranton, PA 18504 (570) 558-5510 Department of Defense Manpower Data Center Stags Report Pursuant to Serv cemenibers Civil Relief Act Last Name: MEAGHER First Name: RANDALL Middle Name: Active Duty Status As Of: Jan-25-2013 Results as of : Jan-25-2013 07:44:52 SCRA 2.3 On Active Duly On Acute Duty StmA Date Active MAY Start Date - Active Duty End Date Status ServioeCOrtpaient NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty WAhn 367 Days d Active Duty SWm Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects %+iere the individual left active duty status vA#wn 367 days preceding the Active Duty Status Date The Member or His+lm Unit Was Notified of a Future Call-Up to Active Duty on Achve Duty Status Date Order Notification Start Date Order Notification End Date Status - Service Component NA NA t.b NA This response reflects whether the individual or }ds7ler 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 active duty status date 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. olal Y1. )I 44.- 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 active duty status date, 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: hftp://www.defenselink.mi1/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date 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). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. 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 (NOAA 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/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 8ET011G6R0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CVF CONSUMER ACQUISITION COMPAN'Y' vs. Randall Meagher 229 Walton St Lemoyne PA 17043-2025 Plaintiff Defendant CIVIL DIVISION NO: 12-4960 CERTIFICATE OF SERVICE 1, 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: Randall Meagher 229 Walton St [,emoyne PA 17043-2025 Date: January 25, 2013 Edwin A. Abrahamsen & Associates. P.C. f. c4h4F aRatchford ' , f Attorney I.D. No.: 862 f 120 N. Keyser Avenu Scranton, PA 18504 (570) 558-5510 , C?%1= C'ONSI_i^,-91 R ACQUISITION COMPANY In the Court of Common Pleas of Plaintiff CUMBERLAND County, Pennsylvania Civil Division vs. Randall Mea-her 229 Walton St Lemoyne PA 17043-2025 NO: 12-4960 Defendant NOTICE OF FILING JUDGMENT Notice is hereby (yiven that a money judgment in the above-captioned matter has been entered against you in the amount of $ )41 a0?. 8y on ---- 8 By: 3, W. 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)