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Home My WebLink About13-2591 Supreme Cad Zf P- -ennsylvania cm O COfll mo J � leas For Prothonotary Use Only: 7 Wil Co Sheet J ��' �`•? F � ,� u - Docket No: n STS CUM�B RLA-N0 County 13 - 41 `iivil�rtYl I,yn The information collected on this form is used solely for court administration purposes. This form does not supplement or replace th filin and service ofplea or oth er papers as required by law or rules of court. Commencement of Action: x Complaint El Writ of Summons El Petition Transfer from Another Jurisdiction El Declaration of Taking �E �. C Lead Plaintiffs Name: Lead Defendant's Name: NATIONAL COLLEGIATE STUDENT LOAN TRUST GARY DONEY T Dollar Amount Requested: [ within arbitration limits I Are money damages requested? 0 Yes 0 No (check one) E]outside arbitration limits O N Is this a Class Action Suit? [ l Yes El No Is this an MDJAppeal? 0 Yes El No A. Name of Plaintiff/Appellant's Attorney: MICHAEL F RATCHFORD, ESQ j Check here if you have no attorney (are a Self. - Represented jPro Se] 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 Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS 0 Intentional El Buyer Plaintiff Administrative Agencies Malicious Prosecution 0 Debt Collection: Credit Card ( Board of Assessment Motor Vehicle El Debt Collection: Other Q Board of Elections Nuisance Q Dept. of Transportation Q Premises Liability Ej Statutory Appeal: Other ! S Q Product Liability (does not include I E mass tort) ® Employment Dispute: Slander/Libel/ Defamation Discrimination C D Other: Employment Dispute: Other Zoning Board T Other: Other: O MASS TORT 0 Asbestos N [2 Tobacco 0 Toxic Tort - DES 0 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste Other: F71 Ejectment [2 Common Law /Statutory Arbitration El Eminent Domain/Condemnation 0 Declaratory Judgment B El Ground Rent E] Mandamus Landlord/Tenant Dispute Q Non - Domestic Relations Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial 0 Quo Warranto Dental n Partition 0 Replevin El Legal Quiet Title ® Other: ® Medical Other: ® Other Professional: Updated 1/1/2011 �Zb� zq IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -2 CIVIL ACTION c/o NCO Financial Systems Inc. 7595 Montevideo Rd - Department 500 Jessup, MD 20794 : Plaintiff vs. n NO: 05 1 GARY DONE w ' r q.v u 53 HONEYSUCKLE DRr�*� �- MECHANICSBURG PA 17050 -3166 Wr -!c �b C:) Defendant )> u 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 s 1os -n5 Pp A77Y a9a,3/8 IN THE COURT OF COM:tiION PLEAS OF - CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -2 CIVIL ACTION c/o NCO Financial Systems Inc. 7595 Montevideo Rd - Department 500 Jessup, MD 20794 Plaintiff VS. NO: GARY DONEY 53 HONEYSUCKLE DR MECHANICSBURG PA 17050 -3166 Defendant COMPLAINT Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -2, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendants as follows: 1. The defendant GARY DONEY is an adult individual residing at 53 HONEYSUCKLE DR MECHANICSBURG PA 17050 -3166. 2. The defendants executed the promissory note for the payment of tuition in which the defendants were required to make monthly payments. 3. The defendants were advanced the proceeds of the loan which were to be used for educational purposes. 4. The defendants failed to make the required payments when due. 5. The balance currently owed by defendants is $13,496.11. 6. 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 $13,496.11 plus costs of suit and any other relief as the Court deems just and appropriate. Respectfully su itte .ichael h. Ratchfo d, Esquire Attorney 20 J.D. Nos. 86285 1. N. Keyser A e Scranton., PA 18 04 niratchford@eaa-law.com Phone: 800 -503 -1665 Fax: 570 -558 -5511 VERIFICATION 1, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -2, am fully familiar with the facts set forth in the within Complaint and arn . authorized to make this Verification on behalf of Plaintiff. 1, 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 Michaelft.'katchfo , Es ire SHERIFF'S OFFICE OF CUMBERLAND COUNTY� Ronny R Anderson x" f F �' " r 1 n F `f Sheriff _ !t. t r} t-� s . ��s�xyp o� G��raPabr��.y� Jody S Smith f 20131M -7 E : 01 Chief Deputy r- r t Richard WStewart - :` C,Ut9�r..ZE..Af Solicitor �=��;CE OF �C 1'�°�S Y L�r��1� National Collegiate Student Loan Trust 2004-2 vs. Case Number Gary Doney 2013-2591 SHERIFF'S RETURN OF SERVICE 05/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Gary Doney, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found"at 53 Honeysuckle Drive, Silver Spring Township, Mechanicsburg, PA 17050. The resident at this address is Gary Doney, Sr. he informed deputies that this Complaint& Notice was for his son Gary Doney, Jr. who now resides in Tennessee, he was unwilling or unable to provide an address for service of Gary Doney Jr. SHERIFF COST: $44.30 SO ANSWERS, June 04, 2013 ROW R ANDERSON, SHERIFF (c)CountySuite Sheritt,Teleosoft,Inc. r •yx `rt Ffrr:;. NATIONAL COLLEGIATE STUDENT • LOAN TRUST 2004-2 In the Court of Common Pleas of • CUMBERLAND County, Pennsylvania Plaintiff • Civil Division vs. • • NO: 13-2591 CIVIL TERM GARY DONEY • Praecipe to Withdraw Civil Complaint Defendant • • • • • • PRAECIPE TO WITHDRAW e•' r,ff r —4 To the Prothonotary of CUMBERLAND County Pennsylvania: coy J Please enter the above Praecipe to Withdraw the Civil Complaint. >a °- fsa Thank you, u -MC4, Michae F. Ratchford squire Edwin A. Abraham--n& Associates, P.C. Lawyer ID# 8628 120 N. Keyser Avenue Scranton, PA 18504