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Home My WebLink About13-1485 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007 -3 CIVIL ACTION I CABOT ROAD 2ND FLOOR MEDFORD, MA 02155 -5117_ Plaintiff vs. Z ASHA FORD NO: - 36 TIPTOP CIR CARLISLE PA 17015 -7741 Defendant and GORDONFORD 9 BACHE ST APT B WELLSBORO PA 16901 -1705 Defendant 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 0 2 �a X IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEP NSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007 -3 CIVIL ACTION I CABOT ROAD 2ND FLOOR MEDFORD, MA 02155 -5117 Plaintiff vs. TASHA FORD NO: 36 TIPTOP CIR CARLISLE PA 17015 -7741 Defendant and GORDON FORD : 9 BACHE ST APT B WELLSBORO PA 16901 -1705 Defendant COMPLAIN Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007 -3, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendants as follows: 1. The defendant TASHA FORD is an adult individual residing at 36 TIPTOP CIR CARLISLE PA 17015 -7741. 2. The defendant GORDON FORD is an adult individual residing at 9 BACHE ST APT B WELLSBORO PA 16901 -1705. 3. The defendants executed the promissory note for the payment of tuition in which the defendants were required to make monthly payments. 4. The defendants were advanced the proceeds of the loan which were to be used for educational purposes. 5. The defendants failed to make the required payments when due. 6. The balance currently owed by defendants is $10,300.20. 7. Plaintiff has declared Defendants to be in default and demands payment of the balance due from the Note. WHEREFORE, Plaintiff requests judgment in its favor and against Defendants in the amount of $10,300.20 plus costs of suit and any other relief as the Court deems just and appropriate. l Resxctfully Michael F. R/N.: , Esquire Attorney I.D. 86285 120 N. Keyse Scranton, PA 4 mratchford@ w.com Phone: 800 -503 -1665 Fax: 570 - 558 -5511 VERIFICATI 1, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007 -3, 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. rte .... 4 &a F. Ratch rd; Esquire f; SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson _"-; U t_ Sheriff ��t�`tity, at t'�srdrataPr�PTr�} Jody S Smith 2013 PR _ �: Chief Deputy AM tip Richard W Stewart J(�1� r�Lri Solicitor National Collegiate Student Loan Trust 2007-3 Case Number vs. Tasha Ford (et al.) 2013-1485 SHERIFF'S RETURN OF SERVICE 03/21/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gordon Ford, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Tioga, Pennsylvania to serve the within Complaint& Notice according to law. 03/28/2013 03:50 PM-The requested Complaint&Notice served by the Sheriff of Tioga County upon Gordon Ford, personally, at the Tioga County Sheriffs Office, 116 Main Street, Wellsboro, PA 16901. Thomas A. Young, 11, Sheriff, Return of Service attached to and made part of the within record. 04/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tasha Ford, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 36 Tip Top Circle, Lower Frankford Twp, Carlisle, PA 17015. Per the current residents they have resided at this address since August 2012 and do not know the defendant.The Carlisle Postmaster confirmed that the defendant is not known at the address given. SHERIFF COST: $64.46 SO ANSWERS, April 02, 2013 RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF TIOGA COUNTY Thomas A.Young 11 Christina Christman Sheriff Civil Division Thomas G.Smith Tammi Perla Chief Deputy Criminal Division NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-3 Case Number vs. GORDON FORD (et al.) CUMBERLAND COUNTY SHERIFF 13-1485 SHERIFF'S RETURN OF SERVICE 03/28/2013 03:50 PM -DEPUTY ROBERT CLARSON SERVED THE REQUESTED COMPLAINT& NOTICE BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: GORDON FORD AT THE TIOGA COUNTY SHERIFF'S OFFICE, 116 MAIN STREET, WELLSBORO, PA 16901. -�—� ERT CLA SON, DEPUTY April 01, 2013 - -- - -- --- --------------------------------------------------- NOTARY � ��N* Affirmed and subscribed to before me this ' day of J S �0�3 (c)CountySuite Sheriff,ieleosoft,inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-3 TASHA FORD and GORDON FORD : CIVIL ACTION Plaintiff : vs. : NO: 13-1485 CIVIL Defendant : Defendant : CD .--4 cn ry -4 O, -r CD C-3 PRAECIPE TO WITHDRAW CIVIL COMPLAINT AGAINST DEFENDANT TASHA FORD ONLY WITHOUT PREJUDICE To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint against Defendant Tasha Ford only without Prejudice. ichael . Ratchford, Es• Lire Edwin A. Abrahamsen Associates, P.C. Lawyer ID # 86285 120 N. Keyser Avenue Scranton, PA 18504 icult,LiaW CueyiVs3 43(196A