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Home My WebLink About13-3401 Supreme Court ofPennsylvania Co U OffCOI17 rn0 Pleas For Prothonotary Use Only: J Cllvil C_ .? Docket No: Ckwhy ", ST� (�( County b In a 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 lmv or rules of court. Commencement of Action: S El Complaint 0 Writ of Summons Petition Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: I NATIONAL COLLEGIATE STUDENT LOAN TRUST 'T Dollar Amount Requested: xl within arbitration limits I Are money damages requested? O Yes 0 No (check one) Ooutside arbitration limits O N Is this a Class Action Suit? O Yes El No Is this an MDJAppeal? 0 Yes Ix{ No A, Name of Plaintiff/Appellant's Attorney: MICHAEL F. RATCHFORD ESQ. F Check here if you have no attorney (are a Self- Represented (Pro Sel 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 ( Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution 0 Debt Collection: Credit Card 0 Board of Assessment 0 Motor Vehicle M Debt Collection: Other 0 Board of Elections 0 Nuisance STUDENT LOAN 0 Dept. of Transportation Premises Liability 0 Statutory Appeal: Other S Product Liability (does not include E 0 Employment Dispute: mass tort) Slander/Libel/ Defamation Discrimination C 0 Other: 0 Employment Dispute: Other O Zoning Board T 0 Other: Other: O MASS TORT 0 Asbestos N 0 Tobacco Toxic Tort - DES Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS 0 Toxic Waste Other: El Ejectment 0 Common Law /Statutory Arbitration El Eminent Domain /Condemnation 0 Declaratory Judgment B 0 Ground Rent 0 Mandamus 0 Landlord/Tenant Dispute 0 Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial 0 Quo Warranto 0 Dental ® Partition 0 Replevin 0 Legal ® Quiet Title 0 Other: ® Medical 0 Other: 0 Other Professional: i Updated 1 /1/2011 ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -1 CIVIL ACTION c/o NCO Financial Systems Inc. 7595 Montevideo Rd - Department 500 Jessup, MD 20794 ':r_, Plaintiff c�n c.) i vs. NO: DEANA EHRHART H 201 W CREEK RD = + NEWBURG PA 17240 -9322 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 ak s o�- �L X w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -1 CIVIL ACTION c/o NCO Financial Systems Inc. 7595 Montevideo Rd - Department 500 Jessup, MD 20794 Plaintiff vs. NO: DEANA EHRHART 201 W CREEK RD NEWBURG PA 17240 -9322 Defendant COMPLAINT Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -1, by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. The defendant DEANA EHRHART (hereinafter "Defendant ") is an adult individual residing at 201 W CREEK RD NEWBURG PA 17240 -9322. 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 $12,320.61. 6. Plaintiff has declared Defendant to be in default and demands payment of the balance due from the Note. y f WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $12,320.61 plus costs of suit and any other relief as the Court deems just and appropriate. Re ct lly b itte Mich F. Ratc or , Esquire Attorney I.D. N s.: 86285 120 N. Keyser ve Scranton, PA 8504 mratchford@ aa- law.com Phone: 800 -503 -1665 Fax: 570 -558 -5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004 -1, am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. M c ael F. Ra h rd, Esquire SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r l:l-0F F I %L '1 THF- PROTHONOTARY, Sheriff Jody S Smith w`��Y rr� 2013 JUL —9 AM fO: .1 Chief Deputy C MBERLAND COUNTY Richard W Stewart Y Solicitor F OF 7�E$ ERI� ` �° PENNSYLVANIA°n FFj National Collegiate Student Trust 2004-1 Case Number vs. Deana Ehrhart 2013-3401 SHERIFF'S RETURN OF SERVICE 06/27/2013 06:20 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint& Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Deana Ehrhart at 201 W. Creek Road, Hopewell Township, Newburg, PA 17240-9322. 01 J SON KINSLER, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, June 28, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Tdeosoit,Inc. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1 CIVIL DIVISION c.-_ ' -,O:K rn Plaintiff "�rn r vs. � , ri DEANA EHRHART : NO: 13-3401-CIVIL C-- ` 201 W CREEK RDA NEWBUR.G PA 1.7240-9322 Defendant ' PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT TO THE CLERK OF JUDICIAL RECORDS: Kindly enter judgment by default for failure to respond to Plaintiff's Complaint in the amount of$12,320.61. Notice of the intent to file a default judgment was served upon the Defendant on July 30, 2013. A copy of the Notice of Intent to Take Default Judgment is allathed hereto and marked Exhibit"A." Ed 'n A. brah se & ociates, P.C. chael F. tchford, E quire Attorney I.D.No.: 862 Attorney for Plaintiff n f *S'4 3 JUDGMENT t�- -aR Sllvl� '\"40jiLe Mtoe AND NOW,this day of-&P,20 1'2NJud ent is hereby entered in favor of the Plaintiff,NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1 and against the Defendant, DEANA EHRHART in the amount of$12,320.61 for failure to respond to Plaintiff's Complaint. ,n PROTHONOTARY -1bV2)3W000 J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1 Plaintiff CIVIL DIVISION vs. NO: 13-3401-CIVIL DEANA EHRHART 201 W CREEK RD NEWBURG PA 17240-9322 Defendant CERTIFICATE OF SERVICE I, Michael F. Ratchford, Esquire, hereby certify that on the date indicated below, I served a copy of the Praecipe for Entry of Default Judgment in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: DEANA EHRHART 201 W CREEK RD NEWBURG PA 17240-9322 Edwin A. Abrahamsen&Associates, P Date: August 30, 2013 icha F. R tchford, Esqu' e ttorney I.D.No.: 86285 120 N. Keyser Avenue Scranton, PA 18504 (570) 558-5510 NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1. In the Court of Common Pleas of CUMBERLAND County,Pennsylvania Plaintiff Civil Division. vs. DEANA EHRHART 201 W CREEK RD NO: 13-3401-CIVIL NEWBURG PA 17240-9322 Defendant NOTICE OF FILING JUDGMENT Notice is hereby given that a money judgment in the above-captioned tter has been entered against you in the amount of$ '� a 3�0 W on I . By: If you have any questions regarding this notice, please contact the filing parry: Edwin A. Abrahamsen&Associates 120 N. Keyser Avenue Scranton, PA 18504 Telephone: (570)-558-5510 (Notice is given in accordance with PA Supreme Court Rule of Civil Procedure No. 236) NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1 In the Court of Common Pleas of Plaintiff CUMBERLAND County,Pennsylvania Civil Division vs. NO: 13-3401-CIVIL DEANA EHRHART 201 W CREEK RD NEWBURG PA 17240-9322 AFFIDAVIT UNDER SOLDIERS AND SAILORS RELIEF CIVIL RELIEF ACT OF 1940 AS Defendant AMENDED State of Pennsylvania County of CUMBERLAND SS: Michael F. Ratchford, Esquire being duly sworn according to law deposes and says that the above named defendant(s): DEANA EHRHART is(are) not in the military service of the United States of America as defined by the Soldiers' and Sailors' Civil Relief Act of 1940 as amended; That the defendant(s): DEANA EHRHART is(are) older than eighteen years of age; That the employment status of the defendant(s): DEANA EHRHART is(are)unknown. Michael F atchford, squire/ Subscribed before me this�day of 20 t3 Notary Public COMMONWEALTH OF PENNSYLVAN=flonte A l Seat,Notary Public zern e County MY .itts]an,3R,Z014 h9� bJI iWI A nt lation of Notaries 120 N.KFYSL=R AVF. 0 EM I'DWIN A.ARRAFIAMSEN SCRANTON,PA. 18504-9701 MICHAEL F.RATC1IFORD (I')1-800-503-1665 (F)570-5-58-5511 SCOT-1"J,REST R1i TURN SMv)CF REQUI:STIiD THE LAW OFFICE OF EDWIN A.ABRAHAMSEN&ASSOCIATES,PC W W W.EAA-LA W.COM July 30,20 133 DEANA EHRHART 241 W CREEK RD NEWBURG PA 17240-9322 Re: NATIONAL COI,LEGIATF. STUDENT LOAN TRUST'2004-1 vs DEANA EHRHART CUMBER1_.4n'U Counts-Civil Action Ao.:13-3401-C11�1L Our file No.: N 1300579AM Dear DEANA EHRHART: Enclosed, please find the Ten Day Notice of Intent to"hake Default in regard to the above- noted matter. Please act accordingly. If you have any questions or wish to discuss your outstanding account, please contact me at (570) 558-5510. Edwin A. Abraha sen & A oc' S' ichael . Ratchford, •squire Enclosure This is a communication from a debt collector in an attempt to collect a debt. Any information will be used for that purpose. 120 N KEYSER AVE SCRANTON,PA 18504 (F)570.558.5510 (F)570.558.5511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL COLLEGIATE STUDENT LOAN TRUST 2004-1 CIVIL ACTION Plaintiff VS. DEANA EHRHART : NO: 13-3401-CIVIL Defendant TEN DAY NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT To: DEANA EHRHART 201 W CREEK.RD NEWBURG PA 17240-9322 Date of Notice: July 30. 2013 IMPORTANT NO'T'ICE PURSUANT TO PA.R.C.P. 237.1(a)(2) YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER AN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 40I EAST LOUTHER STREET CARLISLE,PA 17013 717-243-9400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL. COLLEGIA'T'E STUDENT LOAN TRUST 2004-1 CIVIL ACTION Plaintiff vs. DEANA EHRHART NO: 13-3401-CIVIL Defendant CERTIFICATE OF SERVICE I; Michael F. Ratchford, Esquire, hereby certify that on July 30, 2013 1 served a copy of the Ten Day Notice of Intent to Take Default in the above captioned matter by mailing the same via First Class United States mail, postage prepaid addressed as follows: DEANA EHRIAART 201 W CREEK RD NEWBURG PA 17240-9322 Edwin A. Abrahamsen &Associates. P.C. B _ ichael F. Ratchford, g ire Attorney I.D. No.: 862 5 120 N Keyser Avenu Scranton, PA 1850 (570) 558-5510 SCRA 3.0 Status Repo t ' Pursuant to Service-membim Civil Relief Act Last Name: EHRHART First Name: DEANA Middle Name: Active Duty Status As Of: Aug-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA J� _ - -_- No% NA This response reflects the'mdividuals aGiv_a duty status based on the Active Duty Status Date r• 1 t i .r- Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Daate= Active Duty End Date status Service Component NA r NA 1 r 3 No' '' NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date �A The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA. `� `y`. .� ' NO rr NA E This response reflects whether the individual 0 hisibe un t has received Arty notiticati_on'to report for active duty Upon searching the data banks of the Department of Defense Manpo erData Center;based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. T>he,DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 24BBQD64T034XD0