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HomeMy WebLinkAbout13-2008 Supreme Co»' o P nnsylvania COu of.Commo Pleas For Prothonotary Use Only: C i1�Co�verS he + t Docket No: Sl, -� n / CU . LANb County 13 , do�8 lilvi��Te-fM ti • The information collected on this form is used solely for court administration pwposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by low or ides of court. _ Commencement of Action: S El Complaint ® Writ of Summons ® Petition Q Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiffs Name: Lead Defendant's Name: T NATIONAL COLLEGIATE STUDENT LOAN TRUST VIRGINIA POWELL - 1 Dollar Amount Requested: Owithin arbitration limits Are money damages requested? El Yes 0 N O (check one) []outside arbitration limits N Is this a Class Action Suit? ® Yes O No Is this an MDJAppeal? © Yes li3 No A Name of Plaintiff/Appellant's Attorney: MICHAEL F RATCHFORD ESO ® Check here if you have no attorney (are a Self - Represented jPro Sej Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Alass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional ® Buyer Plaintiff Administrative Agencies ® Malicious Prosecution © Debt Collection: Credit Card 13 Motor Vehicle ❑x Debt Collection: Other 0 Board of Assessment ® Board of Elections ® Nuisance Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S © Product Liability (does not include E mass tort) E3 Employment Dispute: © Slander/Libel/ Defamation Discrimination C ® Other: [3 Employment Dispute: Other © Zoning Board T ® Other: I ' [:] Other: O MASS TORT Asbestos N © Tobacco ® Toxic Tort - DES 13 Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Other: ® Ejectment © Common Law /Statutory Arbitration B [I Eminent Domain /Condemnation © Declaratory Judgment 13 Ground Rent ® Mandamus © Landlord/Tenant Dispute ® Non- Domestic Relations © Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY 13 Mortgage Foreclosure: Commercial ® Quo Warranto ® Dental 0 Partition ® Replevin O Legal ® Quiet Title © Other: ® Medical ® Other: ® Other Professional: Updated 1/1/2011 IN THE COURT OF COMMON PLEAS OF _ CUMBERLAND COUNTY, PENNSYLVANIA —° NATIONAL COLLEGIATE STUDENT m� zrn ro �r LOAN TRUST 2006 -1 CIVIL ACTION Cnr� 1 CABOT ROAD 2ND FLOOR -0> cn o MEDFORD, MA 02155-5117 <a Plaintiff ^a "` VS. VIRGINIA POWELL : NO: c 1D0$ CiVIFETP1 40 MCCOY LN CARLISLE PA 17015-7508 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 40-1 EAST LOUTHER STREET CARLISLE, PA 17013 717- 243 -9400 (� 103. '75 Pb ATr & '984185 x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006 -1 CIVIL ACTION 1 CABOT ROAD 2ND FLOOR MEDFORD, MA 02155-5117 Plaintiff vs. VIRGINIA POWELL : NO: 40 MCCOY LN CARLISLE PA 17015 -7508 Defendant COMPLAINT Plaintiff, National Collegiate Student Loan Trust 2006 -1, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendants as follows: 1. The defendant Virginia Powell is an adult individual residing at 40 Mccoy Ln Carlisle PA 17015 -7508. 2. The defendant executed the promissory note for the payment of tuition in which the defendant was required to make monthly payments. 3. The defendant was advanced the proceeds of the loan which were to be used for educational purposes. 4. The defendant failed to make the required payments when due. 5. The balance currently owed by defendant is $30,771.95. 6. Plaintiff has declared Defendant 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 $30,771.95 plus costs of suit and any other relief as the Court deems just and appropriate. Respe tfully submitted icbael . Ratchfo d, squire Attorney I.D. Nos . 86285 120 N. Keyser A e Scranton, PA 18 04 mratchford @e ' law.com Phone: 800 -503 -1665 Fax: 570 -558 -5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006 -1, 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. A l F. t • ord, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 3 ; PC LLO Jody S Smithy Chief Deputy 21713 MAY . . Richard W Stewart Solicitor Or,F4ECXT SKRIFw CUMBERLAND COUNTY PENNSYLVANIA National Collegiate Student Loan Trust 2006-1 vs. Case Number Virginia Powell 2013-2008 SHERIFF'S RETURN OF SERVICE 05/01/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Virginia Powell, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found"at 40 McCoy Lane, Dickinson Township, Carlisle, PA 17015. Deputies were advised by the defendant's father that she does not live at this address and he has not seen her in over 1 1/2 years, he believes she may residing in either Connecticut or Florida and the Carlisle Postmaster confirms that mail is still delivered to the address provided. SHERIFF COST: $39.78 SO ANSWERS, May 07, 2013 RbNW R ANDERSON, SHERIFF (c)COUMYSuito Sheriff.Te4:osoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006-1 vs. VIRGINIA POWELL and PATRICIA POWELL : CIVIL ACTION Plaintiff : : NO: 13-2008 CIVIL TERM Defendant : Defendant : CAD PRAECIPE TO WITHDRAW To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, ichael F. Ratchford, E Edwin A. Abrahamse Lawyer ID # 86285 120 N. Keyser Aven e Scranton, PA 18504 uire Associates, P.C.