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HomeMy WebLinkAbout14-4314 COMMONWEALTH OF PENNSYLVANIA NOTICE OF APPEAL FROM CQP RT OF COMMON PLEAS MAGISTERIAL DISTRICT JUDGE JUD NT Judicial District, County Of Cumberland COMMON PLEAS No. NOTICE OF APPEAL Notice is given that the appellant has filed in the above Courtof Common Pleas an appeal from the judgment rendered by the Magisterial District Judge on the date and in the case referenced below. NAME OF APPELLANT MAG.DIST.NO. NAME OF MDJ MIDLAND FUNDING LLC 109-1-02 Honorable Elizabeth S. Beckley ADDRESS OF APPELLANT CITY STATE ZIP CODE P.O Box 517 - Essington PA 1.9029 DATE OF JUDGMENT IN THE CASE OF(Plaints fendauo' 06/16/2014 MIDLAND FUNDING LLC vs HRO SALKIC DOCKET No. SIGNATURE OF APPELLANT OR AT EY R AGENT CV-067-2014 This block will be signed ONLY when this notation is required under Pa. If app97lan s C aim Pa. P. .J. No. 1001(6) in action R.C.P.D.J.No. 100813. This Notice of Appeal, when received by the Magisterial District Judge, will before a Magisterial District Judge, A C MPLAINT MUST BE FILED operate as a SUPERSEDEAS to the judgment for possession in this case. within twenty (20)days after filing the NOTICE of APPEAL. Signature of Prothonotary or Deputy PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE (This section of form to be used ONLY when appellant was DEFENDANT(see Pa.R.C.P.D.J. No. 1001(7) in action before Magisterial District Judge. IF NOT USED,detach from copy of notice of appeal to be served upon appellee. PRAECIPE: To Prothonotary Enter rule upon appellee(s),to file a complaint in this appeal Name of appellee(s) (Common Pleas No. )within twenty(20)days after service of rule or suffer entry of judgment of non pros. Signature of appellant or attorney or agent RULE- To appellee(s) Name ofappellee(s) (1) You are notified that a rule is hereby entered upon you to file a complaint in this appeal within twenty(20)days after the date of service of this rule upon you by personal service or by certified or registered mail. (2) If you do not file a complaint within this time,a JUDGMENT OF NON PROS MAY BE ENTERED AGAINST YOU.(3) The date of service of this rule if service was by mail is the date of the mailing. Date: 20 Signature of Prothonotary or Depuly YOU MUST INCLUDE A COPY OF THE NOTICE OF JUDGMENT/rRANSCRIPT FORM WITH THIS NOTICE OF APPEAL. The appellee and the magisterial district judge in whose office the judgment was rendered must be served with a copy of this Notice pursuant to Pa.R.C.P.M.D.J. 1005(A). Fate - o �c� oxo 'S\k3.So c)k �Ae eco �t, A C�, - %aV)41S I aU►� ��, .1 Cl ooy,,) 3684 ?Y 4'j COMMONWEALTH OF PENNSYLVANIA Notice of Jt!{,'�t,�tlC ent/Transcript Civil COUNTY OF CUMBERLAND Case ' PIN Mag. Dist. No: MDJ-09-1-02 Midland Funding LLC MDJ dame: Honorable Elizabeth S, Beckley V. Address: 1901 State Street Fahro Salkic Camp Hill,PA 17011 Telephone: 717-761-0583 Daniel Joseph Santucci,Esq, Docket No. MJ-09102-CV-0000067-2014 P. O, Box 517 Case Filed: 3/3112014 Essington, PA 19029 Disposition Details Disposition Summary (cc-Cross Complaint) Docket Nc Plaint i Defendant Disposition Clisaositi©n Date IBJ-09102-CV-0000067-2014 Midland Funding LLC Fahro Salkic Default Judgment for Defendant 06#15/2014 ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE OF APPEAL WITH THE PROTHONOTARY/CLERK OF COURTOF COMMON PLEAS, CIVIL DIVISION. YOU MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENTITRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL, EXCEPT AS OTHERWISE PROVIDED IN THE RULES OF CIVIL PROCEDURE FOR MAGISTERIAL DISTRICT JUDGES,IF THE JUDGMENT HOLDER ELECT'S TO ENTER THE JUDGMENT IN THE COURT OF COMMON PLEAS, ALL FURTHER PROCESS MUST COME FROM THE COURT OF COMMON PLEAS AND NO FURTHER PROCESS MAY BE ISSUED BY THE MAGISTERIAL DISTRICT JUDGE. UNLESS THE JUDGMENT IS ENTERED IN THE COURT OF COMMON PLEAS, ANYONE INTERESTED IN THE JUDGMENT MAY FILE A REQUEST FOR ENTRY OF SATISFACTION WITH THE MAGISTERIAL DISTRICT JUDGE IF THE JUDGMENT DEBTOR PAYS IN FULL,SETTLES, OR OTHERWISE COMPLIES WITH THE JUDGMENT. F yn JUN 1 i d'C 620140'( Date Elizabeth S.Beckley cern y t.at ttzrs;s a true end correct copy of t74 record of the proceedings containing the judgment. Date Magisterial District Judge _._m._.............. _... _ __...._.._... ......... .... .. ................_ .. MDJS 315 Page 1 of 2 Printed:06/16,12014 1124:3�AM S E C T 0 N A s E C T 1 0 N Supreme Co, rt 5f Pennsylva n ia. CourtrOf.ConllitioiFleas C vil4 er Sl eet CUMBERL ; ~ "..,t'1i Y \ / 441. County For Prothonotary Use Only: Docket No: 14-4314 The information collected on this farm is used solely for court administration purposes. This limn does not .cupltlament or replace the filin t; and service of plcadinb's or other. avers as required by late or rrdes of court. Commencement of Action: Petition Declaration of Taking i Complaint 0 Writ of Summons I11 ❑ 'Transfer from Another Jurisdiction III Lead Plaintitl's Name: MIDLAND FUNDING LLC Lead Def'endant's Nanic: FAHRO SALKIC Are money damages requested? ® Yes 0 No Dollar Amount Requested: N4 within arbitration limits (check one) ll outside arbitration limits Is this a Class Action Suit? 0 Yes .® No Is this an iI D.I Appeal? td Yes 0 No Name of Plaintiff/Appellant's Attorney: Daniel J. Santucci, Esq. _ a Self -Represented [Pro Se] Litigant) ■ Check here it: you have' no attorney (are Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. I f you are making more than one type of claim. check the one that you consider most important. TORT (do not include Mass ')'ort) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle in Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tart) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABL1TY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: 303662 CONTRACT (do not Maude Judgments) O I3uyer Plaintiff Ix! Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other 0 Other: REAL PROPERTY O Ejectment ❑ Eminent Domain/Condemnation ❑ Ground Rent ▪ Landlord/Tenant Dispute ❑ Mortgage Foreclosure: Residential 0 Mortgage Foreclosure: Commercial El Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies 0 Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ®Mandamus Non -Domestic Relations Restraining Order El Quo Warranto ❑ Replevin ❑ Other: Updated 1/1/2011 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 V S. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION NO. 14-4314 -rte .. ..-'c CD, rr 1 C_ - tF:; Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION NO. 14-4314 NOTICE TO DEFEND C= 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 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, 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 SOUTH BEDFORD STREET CARLISLE, PA 17013 PHONE: 800-990-9108 303662 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDEPAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN 303662 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN TI -IE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION NO. 14-4314 COMPLAINT Plaintiff, MIDLAND FUNDING LLC ("Plaintiff'), is a limited liability company with an address of 8875 Aero Drive, Suite 200, San Diego, CA 92123, and is registered to do business in the Commonwealth of Pennsylvania 2. Defendant, FAHRO SALKIC ("Defendant"), has a last known address of 409 Meadow Dr Camp Hill, PA 17011. 3 By this complaint, Plaintiff seeks to recover amounts owed by Defendant. The underlying account that is the basis of this lawsuit is a credit account that Defendant held with creditor GE CAPITAL RETAIL BANK account no. XXXXXXXXXXXX5067 (the "Account"). Prior to filing this complaint, all right, title and interest to the Account were sold and assigned to Plaintiff. Plaintiff owns the Account and stands in the place of the original creditor and is entitled to collect on the Account as if it were the original creditor. To the extent that Plaintiff acts in its capacity as successor -in -interest to the original creditor or its assigns, references herein to Plaintiff may include Plaintiff's predecessor -in -interest. (Please see attached documents) 4. Defendant opened, used, and derived benefit from the Account through Defendant's own use of the Account or by another's use at Defendant's direction. By using the Account, Defendant expressly agreed or impliedly promised to repay Plaintiff. 303662 MIDLAND'S EFFORTS TO RESOLVE THE UNDERLYING OBLIGATION 5. Plaintiff MIDLAND FUNDING LLC owns portfolios of consumer receivables, which it attempts to collect. When working with individual consumers, Plaintiff MIDLAND FUNDING LLC and its affiliates (collectively, "MIDLAND FUNDING LLC") generally attempt to contact consumers like Defendant through several means, all in an effort to establish contact and to resolve the underlying obligation. In doing so, MIDLAND FUNDING LLC attempts to assess each consumer's willingness to pay, through phone calls, letters or other means. MIDLAND FUNDING LLC attempts to exclude consumers from its collection efforts, where MIDLAND FUNDING LLC believes those consumers are facing extenuating circumstances or hardships that would prevent them from making any payments. 6. When MIDLAND FUNDING LLC contacts consumers, it strives to treat consumers with respect, compassion and integrity. MIDLAND FUNDING LLC works with consumers in an effort to find mutually -beneficial solutions, often offering discounts, hardship plans, and payment options. MIDLAND FUNDING LLC's efforts are aimed at working with consumers to repay their obligations and to attain fmancial recovery. MIDLAND FUNDING LLC strives to engage in dialogue that is honorable and constructive, and to play a positive role in consumers' lives. 7. Despite MIDLAND FUNDING LLC's efforts to reach consumers and resolve the consumer's obligations, only a percentage of consumers choose to engage with MIDLAND FUNDING LLC. Those who do are often offered discounts or payment plans that are intended to suit their needs. MIDLAND FUNDING LLC would prefer to work with consumers to establish voluntary payment arrangements resulting in the resolution of any underlying obligations. 8. However, the majority of MIDLAND FUNDING LLC's consumers ignore calls or letters, and some simply refuse to repay their obligations despite an apparent ability to do so. When this happens, MIDLAND FUNDING LLC must decide then whether to pursue collection through legal channels, including litigation like the present action against Defendant. Although the Account is now in litigation, Plaintiff remains willing to explore a mutually -beneficial solution through voluntary payment arrangements, if possible. 303662 FIRST CAUSE OF ACTION (Account Stated) 9. Plaintiff alleges and incorporates by reference the foregoing paragraphs. 10. Within the last four (4) years, Defendant became indebted on the Account to Plaintiff in the sum of $4,238.74 on an account stated in writing by and between Plaintiff and Defendant in which it was agreed that Defendant was indebted to Plaintiff. 11. Plaintiff has made demand on Defendant for repayment of the account stated but Defendant has failed and refused to pay the balance due. 12. As of the date of this complaint, there is a total amount due and owing of $4,238.74 (Please see attached documents) WHEREFORE, Plaintiff demands Judgment in its favor and against the defendant(s) in the amount of $4,238.74 plus court costs and interest. Date: F-.51 By: 303662 MIDL ► 1 F r NDING LLC aniel J. Santucci Attorneys for Plaintiff MIDLAND FUNDING LLC Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION NO. 14-4314 AFFIDAVIT OF NON-MILITARY SERVICE S= - I, being duly sworn according to law, depose and say I am the attorney for the plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Service member's Civil Relief Act of 2004 and any amendments thereto. I also hereby certify that the statements made in the foregoing Affidavit of Non -Military Service are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: By: 303662 Signature Waimar Save motley. Live better, Walmart'; Discover Card 1 Summary of Account Activity , Previous Balance - Other Credits FAHRO SALKICVisit us atwalmari.00mioredh Account Number: 1....._... ... _5067 Customer Service: 1.8604144507 34.238.74 34,77399.74 3 Now Balance j Cred:1 Limit 1 Arseatlle Credit 1 Cash Advance'Quidl Cash Limit i Available Cash Statement Closing Date Days in Billing Cycle '30.00! 53,840 30.00 3700 I 50.00 113012012 29 l Cash Earned Summary i Previous Balance 1(*) Earned This Period ! = Balance Payment Information New Balanoe 10.00 Amount Past Due 50.00 Total Minimum Payment Due 1987.00 Payment Due Date 17/02:2012 Late Payment Warning; It we do not receive your minimum payment by the date listed above, you may have to pay a late tee upto535.00. I Cash News Earning cash back with the Walmarteg Discovere.9 :s easyl Simply use your card everywhere Dr5CAYtYdD 13 accepted. Remember every time you earn lust 510. you vn0 receive a check in your billing statement - it's automatic. Transaction Summary Tran Post Date Date Reference Number Description of Transaction or Credit Amount 11/30 11130 F521000NZ00940340 CHARGE OFF ACCOUNT -PRINCIPALS /53.573.31) 11:30 11/30 F621000Nr'l70999990 CHARGE OFF ACCOUNT 'FINANCE (1085.43) CHARGES' FEES TOTAL FEES FOR THIS PERIOD INTEREST CHARGED 11/30 11/30 INTEREST CHARGE ON PURCHASES 11/30 11/90 INTEREST CHARGE ON CASH ADVANCES TOTAL INTEREST FOR THIS PERIOD 2012 Totals Year -To -Date Total Fees Charged in 2012 Total Interest Changed in 2012 Total Interest Paid in 2012 5175.00 5799.39 5333.34 10.00 50.00 50.00 10.00 interest Charge Calculation Your Annual Percentage Rate (APRIrs tete annual 'interest rate on your account. Type of Balance Expiration Date Annual Percentage Balance Subject 1 o kitetest Charge Rate Interest Rate NA 22.90%(v} $0.00 50.00 NA 25,90%!v; 50,00 50.00 Until Paid Off 22.90%(v)' 30,00 50.00 Until Paid Oft 22.x0 7/(v) 50.00 50.00 Regular Purchases Cast) Advances Quick Casn (::ick Cash Transactions on or before 1211E/2010 Regular Purchases WA Iv) Variable rale 22.909i� 50.00 50.00 PAYMENT DUE 13Y 5 PJrl.1ET1 ON THE DUE DATE NOTICE: We may convert your payment into an electronic debit See reverse for details, Billing Rights and other important irdornlatlon. 3:04 ti";, 1. . 1 ,?11.:<C• t tutu, i •a 3 0:10 1000 -504 .1.,/,3404 Walma 50re mow* ihrebek HI iR,Ytw Detach and mail this portion with your eneck. Do not include any correspondence with your check. otol Minimum Payment Duo 11 11 .................................. 5987.00 Account Number/ 5067 Amount ; Payment One Overlimtl 1 New Balance Past Due I Datta { Amount _.....}......__..........._._.........__.. 50.00 12/02/2012 10.00 I 50.00 Payment Enclosed: l�gjj 1[[ ({FPlease���I6IIuse blue or black ink. ll��liILlllll�/llilli it'll FAHRO SALKIC 406 MEADOW DR CAMP HILL PA 17011-1228 Ne a address or emir? Print changes on beck. Make Payment Ttx WALM.ART DISCOVERIGECR5 PO BOX 950024 ORLANDO. FL 32890-0324 WaImam Saw money. Live bates:. Cardholder News and Information ie ymr account has e deferred interest promotion and you wooed like us to apoty balance, pease car Custemer Service to dim= options that may be available. We understand the Impact of natural et sasters can be dithour and we nope you and your oved ones are safe. if you .need special ass9.aroe with your amount: our representatives are evadable to assist you by calling the number on this statement. a c.0.4 f.040 S _A.:.t30 SY, flhi.+. .. or f.L+v _dal: ;OA .f ...__..!., A BILL of SALE GE Capital Midland PLCC 120 MP — September 2013 For value received and in further consideration of the mutual covenants and conditions set forth in thine= Receivables Purchase Agreement (the "Agreement"), dated as of this 30th day of July, 2013 by and between General Electric Capital Corporation, GE Capital Retail Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller") and Midland Funding, • LLC ("Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer. on September 19, 2013, and as further described in the Agreement. GE Capital Retail Bank By: Ken Wojcik Monogram Credit Services, L.L.C. By: [GfM_ Attorney in Fa Ken Wojcik Title: _EVP Collections & Recovery Date: 1 - Z.. f Date: l°L•(7, General Electric Capital Corporation By: Attorney in Fad Ken Wojcik Date: (4 -'Z . (3. GEMB Lending, Inc. By: Attorney in Faen Wojcik Date: (U • 1. ( 3 RFS I-Iolding, L.L.0 By: SL Attorney , in FKen Wojcik J Date: (0 ` 2--. ( 3 GEM Molding, L.L.0 By: ♦ A 1 1 • Attorney in Fact. en Wojcik Date: (6- Z r3 , Field Field Data ACCTNUM 5067 MKR_FN FAHRO MKR_LN SALKIC MKR_TAXID *****2842 MKR_AD1 409 MEADOW DR MKR_CITY CAMP HILL . M KR_ST PA MKR_ZIP 17011-1228 MKR_WP 0000000000 OPENDATE 20110517 CHGOFF_DATE 20121130 RM SLASTPM T 20120423 LASTPMTAMT 110.00 LOSSAMT 4,238.74 Sale Amount 4,238.74 LASTPURCHDT 20120404 Data printed by Midland Credit Management, Inc. from electronic records provided by General Electric Capital Corporation, GE Capital Retail Bank, GEMO Lending, Inc., Monogram Credit Services, L.L.C,, RFS Holding, L.L.C., and GEM Holding, L.L.C. pursuant to the Bill of Sale / Assignment of Accounts transferred on or about 9/26/2013 in connection with the sale of accounts from General Electric Capital Corporation, GE Capital Retail Bank, GEMS Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C,, and GEM Holding, L.L.C, to Midland Funding LLC. Verification I, Daniel Santucci, Attorney for the Plaintiff, am authorized to make this verification on plaintiffs behalf, as it is being filed in connection with a District Justice appeal and there are time limits. The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: 303662 511 DANIEL SANTUCCI, ESQ. i Daniel J. Santucci, Esq. 'Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC 409 MEADOW DR CAMP HILL, PA 17011 Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS Cumberland COUNTY CIVIL ACTION NO. 14-4314 -3 r c TO THE PROTHONOTARY, Date: PRAECIPE TO SUBSTITUTE VERIFICATION Kindly substitute the verification in the above listed case. By: II 1111 10 1 I 111,1 II II Respectfully Daniel J. Santucci Attorneys for Plaintiff MIDLAND FUNDING LLC Verification Tanya Johnson, being, duly sworn (or affirmed) according to law deposes and says that I am employed as a Legal Specialist for Midland Credit Management, Inc. ("MCM"), servicer of this account on behalf of plaintiff. I am a competent person over eighteen years of age, and make these statements herein based upon personal knowledge of those account records maintained on plaintiff§ behalf I am authorized to make this verification on plaintiff's behalf The facts set forth in the foregoing pleading are true and correct. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. AUG 0 5 2014 Date CA117 Midland Funding, LLC Page - 2 303662 8560735799' L ErD_(OFFIC 1;�L) �t i' it THE P OTHCPO t R': 2014 SEP -2 PM 2: Oil CUMBERLAND COUNTY .PENNSYLVANIA PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT (This proof of service A1UST BE FILED WITHIN TEN (10) DAYS AFTER filing of the notice of appeal. Check applicable boxes.) COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland AFFIDAVIT: I hereby (swear) (affirm) that I served Jz lari wild ' LLE.' v• ss � � ` Fa krU SSI 1 kj a copy of the Notice of Appeal, Common Pleas No.)14`Ei3 (y (date of service) 71)i , 20 141 , , 20 0 by personal service sender's receipt attached hereto. (SWOR AND FIRMS SUBSCRIBED BEFORE ME THIS 2-I 'DAY OF�, 20 Signature of official before whom affidavit was made Title of official My commission expires on(Ql5 , 20'�' COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JOEL RICKETTS Notary Public • PHILADELPHIA CITY, PHILADELPHIA CNTY My Commission Expires Jun 5,, 2017 303662 r • f, upon the Magisterial District Judge designated therein on 0 by personal service 0 by (certified) (registered) mail, sender's receip (certified) (registered) mail, r Signature of avant SENDER: COMPLETE THIS SECTION ■ ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. • Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: rgh,'b $q / k/ c 1.fbq /'leader D ( P711, P4 )7D11 COMPLETE THIS SECTION ON DELIVERY A. Signature x A•ent dressee B. R y (nted Name) C. Date of Delivery 31. Y D. Is delivery address different from item 1'? 0 Yes If YES, enter delivery address below: ,Td No 3. Service edified Mall 0 Registered 0 Insured Mail ❑ Express Mall ❑ Return Receipt for Merchandise ❑ C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Transfer from service label) 7013 2250 0000 6809 7684 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 6� Y:1101"l,ilC.rrf, THE PROT t1ONO 2014 SEP -2 PM 3: 51 ��• rUMBERLAND COUNTY ©FFiei OF YH $ `' PENNSYLVANIA Midland Funding, LLC vs. Fahro Salkic Case Number 2014-4314 SHERIFF'S RETURN OF SERVICE 08/15/2014 08:07 PM - Deputy Jamie DiMartle, 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: Fahro Salkic at 409 Meadow Drive, Wormleysburg Borough, Camp Hill, PA 17011. IE DIMARTLE, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, August 19, 2014 i.:) CountySuite Sheriff, telsoscit, Inc. RONW R ANDERSON, SHERIFF 3 1 Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 14-4314 r-: PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD TO THE PROTHONOTARY: Kindly ENTER a JUDGMENT BY DEFAULT FOR FAILURE TO PLEAD against the Defendant FAHRO SALKIC and for the Plaintiff, MIDLAND FUNDING LLC in the amount of $4,238.74, plus court costs. Plaintiff is not requesting any interest on the amount sought, and requests that interest be waived.. I also hereby certify that a true and correct copy of the Notice required by Pa.R.C.P. 237.1 (a)(2) was mailed separately to the defendant by regular mail. A true and correct copy of the Notice is attached hereto. Date: 14 11110lllllllllllllllllln1 1111 303662 Respectfully Subm By: Daniel J. Santucci, Esq. Attorneys for Plaintiff MIDLAND FUNDING LLC *10.50 PD Ate/ di gaol t5R 3i/395 1{&k'ce miaik , w Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 14-4314 AFFIDAVIT OF NON-MILITARY SERVICE I, 1:)+V ( , being duly sworn according to law, depose and say I am the attorney for the plaintiff and I am authorized to make this affidavit on Plaintiff's behalf. I hereby certify that the defendant is at least 18 years of age and not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Service member's Civil Relief Act of 2004 and any amendments thereto. I also hereby certify that the statements made in the foregoing Affidavit of Non -Military Service are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: By: 303662 MIDLAND U NG LLC re MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS Cumberland COUNTY, PA CIVIL ACTION NO. 14-4314 TO: FAHRO SALKIC 409 Meadow Dr Camp Hill, PA 17011 Date of Notice: 09/15/2014 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGASINT YOU. UNLES 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 ABOVE. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CAN NOT 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 REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 PHONE: 800-990-9108 By Davie". Santucci, Esquire P.O.BOX 517 Essington, PA 19029-051 IMPORTANT DISCLOSURES: Please understand this communication is from a debt collector. This is an attempt to collect a debt. Any information obtained will be used for that purpose. 303662 MIDLAND FUNDING LLC 8875 Aero Drive, Suite 200 San Diego, CA 92123 vs. FAHRO SALKIC Plaintiff, Defendant(s). IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA CIVIL ACTION NO. 14-4314 TO: FAHRO SALKIC 409 Meadow Dr Camp Hill, PA 17011 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a default Judgment has been entered against you in the above proceeding. Dated: /a/80 PROTHONOTARY By: IF YOU HAVE ANY QUESTIONS CONCERNING THE ABOVE, PLEASE CONTACT: Attorney of Record Daniel J. Santucci, Esq. Attorney ID # 92800 P.O. BOX 517 Essington, PA 19029-0517 866-626-5053 303662