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Home My WebLink About13-6435 Supreme Cou `oE "Pennsylvania Cou P A `Pleas For Prothonotary Use Only: Civil Coffer et Docket No: Cui7ae1and`�'� County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filling and service ofpleadings or other papers as required by law or rules of court. Commencement of Action: S iz Complaint l Writ of Summons Petition 0 Transfer from Another Jurisdiction Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: SLM Education Credit Finance Corp. SEAN CRAIG T Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? iX Yes El No (check one) Doutside arbitration limits O N Is this a Class Action Suit? Yes fix! No Is this an MDJAppeal? Yes iX: No A Name of Plaintiff /Appellant's Attorney: FREDERIC I. WEINBERG, ESQUIRE - Check here if you have no attorney (are a Self [Pro 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 E] Debt Collection: Credit Card C' Board of Assessment Motor Vehicle X Debt Collection: Other (] Board of Elections Nuisance Loan Dept. of Transportation 0 Premises Liability Statutory Appeal: Other S Product Liability (does not include � Employment Dispute: F' mass tort) Q Discrimination Slander/Libel /Defamation C Q Other: Employment Dispute: Other [3 Zoning Board � Other: , 1 Other: O MASS TORT El Asbestos N E] Tobacco [] Toxic Tort - DES _ _1 Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS Toxic Waste 0 Ejectment Common Law /Statutory Arbitration B Other: Eminent Domain /Condemnation Q Declaratory Judgment Ground Rent Q Mandamus Landlord/Tenant Dispute ® Non- Domestic Relations N] Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Mortgage Foreclosure: Commercial (] Quo Warranto Q Dental U Partition L Replevin Legal Quiet Title Other: Q Medical Other: Q Other Professional: Updated 111/1011 2165986 THIS IS AN ARBITRATION MATTER. ASSESSMENT OF DAMAGES HEARING REQUIRED. GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351 -0500 SLM Education Credit Finance COURT OF COMMON PLEAS Corp. CUMBERLAND COUNTY 300 Continental Drive Newark, DE 19713 / c:-- VS. DOCKET NO. � SEAN CRAIG �-- - -n 1397 LETCHWORTH RD ti CAMP HILL PA 17011 -7520 =° :7 COMPLAINT IN ASSUMPSIT NOTICE 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 ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY 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 JUDGEMENT 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249 -3166 iz* l l: The defendant(s), for valuable consideration received, executed and delivered to plaintiff a promissory note for the payment of tuition under the terms of which the defendant promised to pay to the plaintiff consecutive monthly payments under the terms and conditions set forth in the promissory note. A true and correct copy of the promissory note and Affidavit of Account are attached hereto, made a part of this complaint and marked Exhibit "A ". 2. Contrary to the terms of the aforesaid promissory note, the defendant(s) failed to make the required payments when due as a result of which the unpaid balance of $5,799.43 became due and payable. 3. As a result of said default, defendant(s) is /are indebted to plaintiff in the amount of $5,799.43. .4. Plaintiff has made demand upon the defendant(s) for payment of the amount due but the defendant(s) has /have failed to pay the said sum or any part thereof. WHEREFORE, plaintiff claims of the defendant(s) the sum of $5,799.43. GORDON & WE NBERG, P.C. BY: FREDERIC VXINBER G, ESQUIRE JOEL M. F K, ESQUIRE Attorney for Plaintiff P01C.SM1 2165986 SLM Education Credit Finance Corp. SEAN CRAIG 9339590353 -03 VERIFICATION I hereby state that I am the agent for the plaintiff herein, and that the facts set forth in the attached Affidavit which is incorporated by reference in the foregoing Complaint in Civil Action are true and correct to the best of my knowledge, information and belief and is based upon information which plaintiff has furnished to counsel. The language in the Complaint is that of counsel and not of plaintiff. To the extent that the contents of the Complaint are that of counsel, plaintiff has relied upon counsel in making this verification. This verification is made subject to 18 Pa.C.S. §4904 which provides for certain penalties for making false statements. M ry Ka ue itigation Assistant EXHIBIT "A" 2165986 SLM Education Credit Finance Corp. SEAN CRAIG , Account No. 9339590353 -03 State of Indiana § § County of Hamilton § AFFIDAVIT I, Mary Kay Mauer, Litigation Assistant, being of full age, hereby certify as follows: 1. I am more than 19 years of age and am competent to make this affidavit. 2. I am employed by Sallie Mae, Inc., as a Litigation Assistant. I am authorized to make this affidavit on behalf of Sallie Mae, as administrator and agent for SLM Education Credit Finance Corp. 3. I am familiar with the facts and circumstances in connection with this account and have been authorized to make this affidavit in the above referenced case. 4. In the ordinary course of business and as a regular business practice, Sallie Mae, Inc., as Administrator and Agent for SLM Education Credit Finance Corp. compiles business records memorializing account activity and transactions at or near the time they occur. 5. Entries in the files and business records of Plaintiff are made contemporaneously with transactions in order to preserve the accuracy of the transaction. 6. Account information and business records regarding Plaintiff's accounts are maintained by Sallie Mae, Inc., as Administrator and Agent for SLM Education Credit Finance Corp. . 7. I have custody and control of the files and business records relating to this account. 8. There remains a balance due plaintiff from defendant in the amount of $5,799.43 as of September 17, 2013. 9. Based upon the account information that I reviewed, the Defendant is not an infant or incompetent person. I have input the Defendant's name in the Manpower Department of Defense database and based upon that review, the defendant is not on active duty with the Armed Forces of the United States of America or its allies. I affirm under the penalty of perjury that the above facts are true and correct to the best of my belief. Mary R&V b&ue# Sallie Mae, Inc. As Administrator and Agent for SLM Education Credit Finance Corp. IN WITNESS WHEREOF I have hereunto subscribed my name and affixed my official seal on September 18, 2013. Notary Public Notary Name: Kimberly L Peace My Commission Expires on: June .18, 2018 Within and for the County \ o ` �f�� i �ncock \`` ��rRIY L ' o And State of Indiana pock co' • 9 C� �''• p01ARY PUBLI C Notary Number: 617811 - CO' m. as »81� OTARY SEAL INb y OF NO TRUE AND EXACT COPT' OF THE ORIGINAL 93'0 5002:J£.TJ9i ITT Signature Opportunity Loan® WRONG Ac2005-2006 err Application and Promissory Note For Loans First blsbursed Through May 31, 2006 XC Lendar Nmta Commerce Bank/Delaware N.A. Lender City Wilmington I Lendersuie DE Lender coda Section A: Borrower Information Please read Instructions before completing this section. Last Name and SusEa First Name MI CRAIG SEAN Pernaneni Address (No PO Doxa) City Sure -- 7 i c' 4810 JONESTOWN ROAD APT 20 HARRISBURG PA 17109 Permanent Photo Numbs Time At Addrua 1 year" , Months If less than 1 year. vide prior sad iras - , P— ,Addraw City Suit ZiP Code I Adsh— while In S,' —I Gay Sulu Zip Coda phone Number while in scboed Dam ofblrth (rnm4lNyy' Email Addre» Citizenship (select oae) S) U.S dtiun + b) Nm.Citiam Permanent Raltlmt . c) reian Resident Have evwde m amsdsnlom? Nmr: Fa hart rseindrumas Yes No r If see instrscaom roarrequirad action Total Loan Arnnant Requested Wo encourage you to borrow conservatively, but try to borrow the full A—.t requested Is for the ; From (mm / yy) To (mm I yy) $ nmunt y ou raced s0 yeii will not have to submit another a bastion. See instructions Eamllmean period: School Name city , Sus ITT TECHNICAL INSTrtUTE MECHANICSBURG PA Grade Levan (Re er to Instructions) Course or St y (Refer to natnacuons) Student I= Education Debt Dt 1 CDC Tod Federal _ S m=s TotJ Non- Fodend Prism S 0 Reference - - Yes mute provide act adult reference other than the cosigners Lest Names sad Suni. First Name MI Relationship to Bortarser CRAIG 1 JOHN Address (No PO Bees) City St -tan Zip Code xphible) 233 LUTHER r•IACE HARRISBURG PA 17111 Section B: Cosigner Information Please read instructions before completing this section. As a cosigner, you am not required to add a second cosigrer. However, iryou want a second cosigner's Income en! debts to be considered in the Wan declaim, please have hiMhercmnplete the second ctaigner seedoiu Second cosigner must reside at primary cost ner'a address. Social Seumity Namber last Nos cod Safnx First Name MI Address (No PO Domes) City Sots Zip Code Phone Number DxeofHlnh (mm'dlyy) I Arlthaa Haeyouevadebulsed Bonk Nem Checking Account err Savirnglt Ate set ) a) ci b) P loan? No e: ti instr proem Employer Nu Fmp ity, i b Oruas Munthly In can N rt er gNRcnt n P. separate onalnteean eo u a f a not Sara S Reference - - Yes vide o Lest Name end Sure t IuiO Address (No PO Item Phone Number (cell phone Dui Z;iatiblel Second Cosign Social Security Nunes Name M. Final Name MI bib Date of Dinh(mMddlyy) ((aye you nvsk mxba lean? Culsernhip (sties oral e) U.S, eleven h) Non -Chi¢n P—.-,A Reaidcnt_ Ya / No Nos: Por option It see insawdam Presort Gmployer Name C•rnp Dyer A dro Sute, Zip Code) work Phene Number Gross Monthly Salary (See Interactions) User Monthly Poymma S $ Section C; Borrower and Cosigners) Signature CAUTION — IT IS IMPORTANT THAT YOU No1ka to Crammer (a) Do not sign this bdote you antidote 1 declare t the iMorrttatim provided above is true aced complete to the fsen of my THOROUGHLY READ THE CONTRACT Pomiacory e evm ne lfedi —ire advised (b) Do not Sipe knowledgemdbelie f. Ih. veroadthe P —i.— yNme..mvanyimgddsopplintioa is if it ennui lank apsees. (e) You ere -allied re am and the Notices to Coaig,,r(.), rr.mohu to pay; lamely.rd severally cosh the ether BEFORE YOU SIGN 1T. WE , THE ...I Dopy o y a :t you sign. (d) You taw Ile right signer below, I promotes to pay the lmdas m any ether holder of this tom all aunt COSIGNER(S),HAVEREADTHEAPPLICA .Layne pay' aid— she uepoidbat.— due ..der dielasctama she urnroo rum NomtaaaryNme ,pfasinat— A a .11ousrchars.alum COSIGNER NOTICE. this cep I ar.1 you relay be emitted ter. partial named or many becars duo The bona and conditimPromissory s act ronh in the Pro Nose slitute the n can charge. thetrslre agreement between us. Borrower Signature (seal) Date - Cosigner Signature (if applicable) (seal) Date Second Cosigner Signature (if applicable) (seal) Date Section D: School Certification Must be completed by an authorized school official. Scheel Name Scheel CoddDrm.It niahursernem lean (mmldd/yy) Dshrmement Amount ITT For the Enrollmen Period (nos to each 112 enanthst Grade te.el(Circle ) plow afar w(rs:ruaionr, Q / Undergraduate 2 1 4 S I. v ! 4W Form Date (mralddlyyl 11.2 Ta tleu (mm/dd/yy) 09_02_06 Umduate A H C D 2. / 1,, 1/ Earollrnrct Suatus(Clmle oat) Course ofstudy(circle one) Andelpsmd Gred Dole(ma✓dd/yy) J ct�Y 1. t Full - firm Half - time FRN Opp t, _I�J Total caninedAmount: s I hereby certify that the Borrower is eligible for a S ignaturc Student Loan; that the Total Certified Amount does not exceed the student's cost of attendance minus other financial aid; thatW School will, at the request of the lender, provide the lender with subsequent information rcgarding the Borrower's whereabouts; that this School will comply with all icable loan li i s and rovisions• and that information rovided in Sections A and B is true two late and correct to the best cafmy knowledge and belief. Authorized sc TARA E HARVEY Carafroation bent Bleoronically Sign mtUd ilk: Yes I Nu PDF Return Application To: SA A* Mae Servinng m PO Box 59030 • Panama City, FL 32412 (Copyri sears Mee 2000 -0 moos) XC2004 -T I II 1911111111111111 IRE 11111111111 [ III! Hill QII IIII IIIIIII III IN 1111101 1111111! I� qll IIII IIII VIII lllf pill IIII 0111111111111111111111111111 Oil p ➢I IIII III) IIII TRUE AND EXCACT COPY OF THE ORIGINAL ere sanzr.Er� »r Opportunity Loan Authorization Form School Nam ITT School Code 007329 -05 Re: Authorization to Disburse Opportunity Loan Funds i i The student listed below has been approved to receive educational funding for the 05106 academic year through the Opportunity Loan Program: US Citizen or Penn Resident Student ( XC - OPP) Q Foreign Student (XC -FRN) 0 i Student's Name: Seen craig Student's SSN: Loan Amount: $ 2204,00 Loan Period: 11=2005 to 09/0 Status: 0 F / H (select one) Grad Date: 11 - - 2007 Grade Level: 01 Disbursement Dates: (1) 08/29/2005 (2) 11/21/2005 (3) 03/06/2006 (4) •Reuuired INS Documentation for Student Approvals Please provide one of the following! Front and back copy of INS Forth 1.551 (permanent residents) Copy of J -1 visa Copy of F -1 visa, Copy of H -lB visa, Copy of 1.94 and a copy of passport (with photo) Copy Form 1 -688B Copy Form 1 -766 By signing below, ITT certifies that no applicant was refused or approved for this loan on the basis of his or her race, color, religion, national origin, sex, sexual orientation, marital status or age (provided the applicant has the capacity to enter into a binding contract), the fact that any part of his or her income derives from a public assistance program, or the fact that the applicant has in good faith exercised any right under the federal Consumer Credit Protection Act or any state law upon which an exemption to the •I has been granted by the Federal Reserve Board. Authorized Approver 10/04/2005 (Signature) (Date) Tara E. Harvey (Printed Name) (Phone Number) NOTE: Applicants with prior student loan defaults are not eligible for Opportunity Loans approval. Signed, completed applications, including required INS documentation, must be provided to Sallie Mae prior to disbursement. Send Completed Form To Mail: SMSC/FL Fax: (850) 767 -7477 PO Box 59030 Attn: Private Credit Originations Panama City, FL 32412 -9030 Revised 04101104 Wild* Department of Defense Manpower Data Center Results as of: Oct -07- 201310:42:17 SCRA 3.0 . LQ • r Status Depart _ PUTSUant to SeNicememben Civil Relief Act Last Name: CRAIG First Name: SEAN Middle Name: Active Duty Status As Of: Oct -07 -2013 On Active Duly On Active Duty Status Date Active Duty Start Dale Active Duly End Date Status Service Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duly Status Date Left Active Duty Within 307 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duly Status Dale Order Notification Start Date Order Notification End Dale Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data 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. Ohl A Mary M. Snavely- Dixon, Director Department of Defense-. Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical pre and other eligibility systems. The 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: http: / /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: C4F9Z9CEHOB9JBO SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff '0 R 'rHE PRO"HON Jody S Smith Chief Deputy r 3 NOV 20 AM [1: 01 Richard W Stewart Solicitor OFFICE OF THE SVERIFF IMMBERLAND COUNTY PENNSYLVANIA SLM Education Credit Finance Corp. vs. Case Number Sean Craig 2013-6435 SHERIFF'S RETURN OF SERVICE 11/15/2013 02:30 PM- Deputy Shawn Harrison, being duly sworn according to law, sqrved e equested Complaint & Notice by"personally" handing a true copy to a person representing es be the Defendant, to wit: Sean Craig at 1397 Letchworth Road, Lower Allen, Camp Hill, SqkWN_A40<SON, DEPUTY Cl/ SHERIFF COST: $44.95 SO ANSWERS, November 18, 2013 RbNNTY R ANDERSON, SHERIFF (C)CountySuite Sheriff,TelLosoft,Inc. 21659,:Qf GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE a 3 !; f 'f ; Identification No. : 41360 ((€(p (( A' ( [ jf JOEL M. FUNK, ESQUIRE PENNSYLVANIA Identification No. : 41200 PENNSYLVANIA 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 4841351-0500 SLM Education Credit Finance COURT OF COMMON PLEAS Corp. CUMBERLAND COUNTY I= VS. DOCKET NO. : 13-6435-CIVIL SEAN CRAIG PRAECIPE FOR ENTRY OF JUDGMENT FOR WANT OF AN ANSWER ASSESSMENT OF DAMAGES, VERIFICATION OF ADDRESS AND NON-MILITARY SERVICE TO THE PROTHONOTARY: Enter judgment for want of an answer for plaintiff and _ against defendant (s) SEAN CRAIG above named only and assess damages certified to be calculable as a sum certain from the complaint, as follows: Principal $5, 799. 43 Interest from 12/31/2009 @0% $ . 00 Costs (Complaint & Service) $148 . 70 Less : Payment on Account ( $ . 00) Total: $5,948 . 13 Understanding the false statements made herein are subject to penalty under 18 Pa.C. S.A. §4904, Unsworn Falsification to Authorities, I verify that : 1 . The last known addresses of the parties are: SLM Education Credit FinanceCorp. and that the last known address of �«�7 3 defendant, SEAN CRAIG, 1397 LETCHWORTH RD, CAMP HILL PA 17011-7520 . 2 . The annexed notice (s) of intention to file thisL�- praecipe was (were) mailed to all parties, defendant and to their record attorneys, if any, after default occurred, and at least ., ten days prior to the date of filing of this praecipe. 04-G£, / 3 . The said defendant (s) is (are) not in the military service of the United States or otherwise within the coverage of the Soldiers and Sailors Civil Relief Act and is (are) over 18 years of age. AND NOW, this day of 20,6Judgment is entered in favor of the plaintiff (s) and against defendant (s) by default for want of an answer nd ages ssessed a phe sum of $5, 948 . 13 as per the above cer fica on. Pro o aT GORDON & WEINBERG, BY: FREDERIC A . W.RINBERG, ESQUIRE JOEL M. ESQUIRE Attorney for Plaintiff 2165986 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 SLM Education Credit Finance Corp. COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. DOCKET N0. 13-6435-CIVIL SEAN CRAIG NOTICE OF INTENTION TO TAKE DEFAULT TO/PARR SEAN CRAIG 1397 LETCHWORTH RD CAMP HILL PA 17011-7520 DATE OF NOTICE/FECHA DEL AVISO: December 6, 2013 _ IMPORTANT NOTICE _ YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 GORDON & WEINBERG, P.C. BY: FREDERIC 1 . WEt7BERG, ESQUIRE JOEL M. FINK, ESQUIRE P10D Department of Defense Manpower Data Center Results as of:Deo-,8-201311:01:05 SCRA 3.0 �+ + Status Rtport Pursuant to Semicememben Civil Relief.Act Last Name: CRAIG First Name: SEAN Middle Name: Active Duty Status As Of- Dec-16-2013 On Active Duly On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the in ividuals'active duty status based on the Active Duty Status Date Left Active Duty within 367 Days of Active Duty Statics Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duly on Active Duty Status Date Order Notification Start Date Order Notification End Date status Semce Component NA I NA No NA This response rellecls whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data 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 1DENTIFYAN INDIVIDUAL. iA Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Al The Defense Manpower Data Center(DMDC)is an organization of the Department of defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The 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:http://www.defenselink.mil/faq/os/PC09SLDR.htmi, 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 3 67 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(NdAA 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 girth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: L6U3A832WO22NBO 2165986 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360 JOEL M. FLINK, ESQUIRE Identification No. : 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 SLM Education Credit Finance COURT OF COMMON PLEAS Corp. CUMBERLAND COUNTY VS . DOCKET NO. : 13-6435-CIVIL SEAN CRAIG 1397 LETCHWORTH RD CAMP HILL PA 17011-7520 NOTICE Pursuant to Pa. R.Civ. P. 236 of the Supreme Court of Pennsylvania, you are hereby notified that a judgment has been entered against you in the above proceeding as indicated below. /XL Judgment by Default $5,948.13 �L Money Judgment $ LL Judgment on Award of Arbitrators$ L1, Judgment on Verdict$ IF YOU HAVE ANY QUESTIONS CONCERNING IS NOTICE, PLEASE CALL ATTORNEYS: FREDERIC I . WEINBERG OR JOE M. NK QUIRES A HIS TELEPHONE NUMBER: 484/351-0500 PROTHONOTARY The Law Offices of Frederic I. Weinberg & Associates, P.C. BY: Frederic I. Weinberg, Esquire Identification No.: 41360 Joel M. Flink, Esquire Identification No.: 41200 375 E. Elm Street, Suite 210 Conshohocken, PA 19428 — 484/351-0500 2165986 - --SLM Education Credit Finance Corp. 300 Continental Drive Newark, DE 19713 vs. EmESEAN CRAIG 1397 LETCHWORTH RD CAMP HILL PA 17011-7520 and Metro Bank 3201 Trindle Rd. =Camp Hill, PA 17011 GARNISHEE(S) TO THE PROTHONOTARY: COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 13 -6435 -CIVIL PRAECIPE FOR WRIT OF EXECUTION Issue writ of execution in directed to the Sheriff of (1) against SEAN CRAIG (2) against Metro Bank the above matter, Cumberland County; defendant (s) and garnishee(s) (3) Amount Due Interest from December 23, 2013 Costs Prothonotary fee Sheriff fee (4) Less: Payments on Account TOTAL 4 LI at NE41-6 anAk dCt‘ st)%11. Alf3,,qS Pd -CxAk es. SO. $5,948.13 $357.87 $.00 FREDERIC I. WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff 41-3 Ot-1 tR,QrlS 3T) THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net SLM EDUCATION CREDIT FINANCE CORP. Vs. SEAN CRAIG WRIT OF EXECUTION (Pa R.C.P. 3252) NO 13-6435 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs against SEAN CRAIG, 1397 LETCHWORTH ROAD, CAMP HILL, PA 17011 Defendant (s) (1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein; (2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of METRO BANK, 3201 TRINDLE ROAD, CAMP HILL, PA 17011 GARNISHEE(S), as garnishee, (Specifically describe property) and to notify the garnishee that (a) an attachment has been issued; (b) except as provided in paragraph (c), the garnishee is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof;. (c) the attachment shall not include (i) the first $10,000 of each account of the defendant (s) with a bank or other financial institution containing any funds which are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (ii) each account of the defendant (s) with a bank or other financial institution in which funds on deposit exceed $10,000.00 at any time if all funds are deposited electronically on a recurring basis and are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law. (iii) any funds in an account of the defendant (s) with a bank or other financial institution that total $300 or less. If multiple accounts are attached, a total of $300 in all accounts shall not be subject to levy and attachment as determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general exemption provided in 42 Pa.C.S. § 8123. (3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession 1 of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added as a garnishee and is enjoined as above stated. Amount Due $5,948.13 Interest FROM DECEMBER 23, 2013 - $357.87 Attorney's Comm. % Attorney Paid $268.95 Date: 1/8/15 (Seat) Plaintiff Paid Law Library $.50 Due Prothonotary $2.25 Other Costs David D. uell, Prothonotary By: Deputy REQUESTING PARTY: Name : FREDERIC I. WEINBERG, ESQUIRE Address: LAW OFFICES OF FREDERIC I. WEINBERG & ASSOCIATES, P.C. 375 E. ELM STREET, SUITE 210 CONSHOHOCKEN, PA 19428 Attorney for: PLAINTIFF Telephone: 484-351-0500 Supreme Court ID No. 41360 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW I. $300 statutory exemption 2. Bibles, school books, sewing machines, uniforms and equipment 3. Most wages and unemployment compensation 4. Social Security benefits 5. Certain retirement funds and accounts 6. Certain veteran and armed forces benefits 7. Certain insurance proceeds 8. Such other exemptions as may be provided by law 2 Ronny R Anderson. Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY E13 .w } t"...�"R01 01 Cittu}"" OF THE St*wRIFF 7.615 t► NI 12: 59 CUMBERLA.NO PENNSYLVANIA COUNT SLM Education Credit Finance Corp. vs. Sean Craig Case Number 2013-6435 SHERIFF'S RETURN OF SERVICE 01/13/2015 08:50 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Metro Bank, 65 Ashland Avenue, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Suzzanne Yingling, Supervisor, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on January 14, 201 to-ean Craig at 1397 Letchworth Road, Camp Hill, PA 17011-7520. January 14, 2015 (c) CountySuite Sherif', Toleosoff. 'nc. WILLIAM CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF