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HomeMy WebLinkAbout13-2011 Supreme C0 >3 of r'ennsylvama Cou f f +C (An mo v leas For Prothonotary UseOn(v: 7 C'1 ,1l C'VS CCt Docket No: Cu County 13-6Dll IvIIIC'P�i L,, The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or otherpopers as required by law or rules ofcourt. Commenkement of Action: 0 Complaint ❑ Writ of Summons ❑ Petition ® Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiffs Name: Lead Dcfendant's Name: NATIONAL COLLEGIATE STUDENT LOAN TRUST VIRGINIA POWELL T Dollar Amount Requested: Elwithin arbitration limits I Are money damages requested? 0 Yes ® No O (check one) ©outside arbitration limits N Is this a Class Action Suit? ❑ Yes M No Is this an MDJAppeal? ® Yes El No A Name of Plaintiff/Appel[ant's Attorney: MICHAEL F RATCHFORD ESQ ❑ Check here if you have no attorney (are a Self- Represented jPro 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 Alass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ® Intentional ❑ Buyer Plaintiff Administrative Agencies ® Malicious Prosecution ® Debt Collection: Credit Card ❑ Board of Assessment ® Motor Vehicle [Fl Debt Collection: Other ❑ Board of Elections ❑ Nuisance Dept. of Transportation S [3 Premises Liability B Statutory Appeal: Other ® Product Liability (does not include E mass ton) E3 Employment Dispute: ® Slander/Libel/ Defamation Discrimination C ® Other: ® Employment Dispute: Other ❑ Zoning Board T © Other: I _ ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco © Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: ® Ejectment ❑ Common Law /Statutory Arbitration B E3 Eminent Domain/Condemnation ❑ Declaratory Judgment ® Ground Rent Mandamus ❑ Landlord/Tenant Dispute Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ® Quiet Title ❑ Other: ❑ Medical ❑ Other: E3 Other Professional: Updated 1 /1!2011 IN THE COURT OF COMMON PLEAS OF c �_ CUMBERLAND COUNTY, PENNSYLVANIA z NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005 -3 CIVIL ACTION "c,, cn u 1 CABOT ROAD 2ND FLOOR MEDFORD, MA 02155-5117 Plaintiff VS. 2.3 VIRGINIA POWELL NO: 13- ab I I �IV�ITerm 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 5 $103.75 P13 ATT'( C (99 738 �� asq�s8 x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005 -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 2005 -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. 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 defendants is $31,936.73. 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 Defendant in the amount of $31,936.73 plus costs of suit and any other relief as the Court deems just and appropriate. W hf bmitte rd squire Attorney I.D. No .: 86285 120 N. Keyser e Scranton, PA 1 504 mratchford @e - law.corn Phone: 800 -503 -1665 Fax: 570 -558 -5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005 -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. is c4FF. Ra te o , Esquire SHERIFF'S OFFICE OF CUMBERLAND COU.NT�( , Ronny RAnderson (1 1iE PROTHOIAO AF;'Y Sheriff 01 � Jody S Smith 2013 SAY —8 PM 31 13 Chief Deputy � 4 Richard W Stewart � �~'�`" CUMBERLAND COUNTY Solicitor ;a F,,;C+xI=,,txy F:lF PENNSYLVANIA National Collegiate Student Loan Trust 2005-3 Case Number vs. Virginia Powell 2013-2011 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 L (c)CounlySuite Sheriff,Toleosoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005-3 vs. VIRGINIA POWELL and PATRICIA POWELL : CIVIL ACTION Plaintiff : : NO: 13-2011 CIVIL TERM Defendant : Defendant : PRAECIPE TO WITHDRAW To the Prothonotary of CUMBERLAND County Pennsylvania: Please enter the above Praecipe to Withdraw the Civil Complaint. Thank you, Michael F. Ratchf• d, Esquire Edwin A. Abrah. sen & Associates, P.C. Lawyer ID # 862:5 120 N. Keyser A enue Scranton, PA 18504 —4c:3 -m