Loading...
HomeMy WebLinkAbout13-2010 Supreme Cou"! of ennsylvama rij f,�CA 1 Conomoro Pleas For Prothonotary Use Only: oder Sheet TJ1 ji Docket No: CUf LAN I County 0-05 O'lvllTero The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules ofcourt. Commencement of Action: S '®x Complaint 0 Writ of Summons Q Petition' © Transfer from Another Jurisdiction 13 Declaration of Taking E C, Lead Plaintiffs Name: Lead Defendant's Name: T NATIONAL COLLEGIATE STUDENT LOAN TRUST VIRGINIA POWELL Dollar Amount Requested: S Mthin arbitration limits I Are money damages requested? ❑x Yes 0 No (check one) ©outside arbitration limits O N Is this a Class Action Suit? ® Yes El No Is this an MDJAppeal? © Yes El No A Name of Plaintiff /Appellant's Attorney: MICHAEL F RATCHFORD ESQ ® Check here if you have no attorney (are a Self - Represented Pro Sep 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 Aloss Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional © Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card [j Board of Assessment 0 Motor Vehicle 19 Debt Collection: Other ® Board of Elections Nuisance Dept. of Transportation ® Premises Liability Statutory Appeal: Other S ® Product Liability (does not include E mass fort) © Employment Dispute: © Slander/Libel/ Defamation Discrimination C 0 Other: ® Employment Dispute: Other ® Zoning Board T 13 Other: I " 0 Other: O MASS TORT 0 Asbestos N ® Tobacco ® Toxic Tort -DES ®ToxicTort - Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste Other: 13 Ejectment Common Law /Statutory Arbitration B [3 Eminent Domain/Condemnation [3 Declaratory Judgment ® Ground Rent ® Mandamus ® Landlord/Tenant Dispute ® Non- Domestic Relations © Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Q Mortgage Foreclosure: Commercial ® Quo Warranto . ® Dental 1] Partition 13 Replevin ® Legal ® Quiet Title © Other: [] Medical ® Other: © Other Professional: Updated 111/1011 J T IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA o c --s NATIONAL COLLEGIATE STUDENT mp= Y L m F OAN TRUST 2006 -3 CIVIL ACTION 70 ;? 1 CABOT ROAD 2ND FLOOR Cny r_n o -' MEDFORD, MA 02155 -5117 �o sue- Plaintiff C-) a z VS. VIRGINIA POWELL NO: 13 -c1DID C - Teno 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 401 EAST LOUTHER STREET CARLISLE, PA 17013 717- 243 -9400 IDS. `15 PO IpIN # 189) C� iaoa�u� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006 -3 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 -3, 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. 3. The defendant executed the promissory note for the payment of tuition in which the defendant was required to make monthly payments. 4. The defendant was advanced the proceeds of the loan which were to be used for educational purposes. 5. The defendant failed to make the required payments when due. 6. The balance currently owed by defendant is $25,975.15. 7. 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 Defendant in the amount of $25,975.15 plus costs of suit and any other relief as the Court deems just and appropriate. Respectfully srA Mic ael . Ra Attorney I.D. 120 N. Keyser Scranton, PA rnratchford@e Phone: 800 -503 -1665 Fax: 570 -558 -5511 4 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006 -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. 1 2 �V XA Ratchford uire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson 31 THIL PR T:)q( ,YY1-Ar)y Sheriff 2013 MAY "8 Ptl 31-Jody S Smith Chief Deputy r � CUMBERLAW COUHTY Richard W Stewart PENNSYLVANIA Solicitor ri^ 09 TN_°34SRI National Collegiate Student Loan Trust 2006-3 Case Number vs. 2013-2010 Virginia Powell 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 RUNNY R ANDERSON, SHERIFF yn CnuntySuite Shedff,Tel>cscft,Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson c,of j ; t^#3t i Sheriff Jody S Smith .lIm6e,/, i1 7� 'r Q Qi Q� r, Chief Deputy . Richard W Stewart Z i3 J N 21 MI 1O= C1fM8ERAN3 (jJ Solicitor - Cc-c S.ERtFc PENNSYLVANIA Fulton Bank, N.A. Case Number vs. 2013-2110 Arthur Clark SHERIFF'S RETURN OF SERVICE 06/17/2013 07:27 PM- Deputy Tim Black, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Arthur Clark, pursuant to Order of Court by"Posting"the premises located at 220 Reno Avenue, New Cumberland Boro, New Cumberland, PA 17070 with a true and correct copy according to law. TIM LA , DEPUTY SHERIFF COST: $53.67 SO ANSWERS, r► . June 18, 2013 RONR ANDERSON, SHERIFF i<;!Cau^tyE ui e:iherL",lel:asc`t.!. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006-3 : CIVIL ACTION Plaintiff : vs. : NO: 13-2010 CIVIL TERM VIRGINIA POWELL and PATRICIA POWELL Defendant : Defendant : --r; - C'� 73' CD CD S -71 "o c PRAECIPE TO WITHDRAW To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, ‘°41r r �r ichael F. Ratchf. d, Esquire Edwin A. Abrah. ' sen & Associates, P.C. Lawyer ID # 862:5 120 N. Keyser Avenue , Scranton, PA 18504 r