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Home My WebLink About07-1894GREGG L. MORRIS, ESQ. PATENAUDE & FELIX, A.P.C. 213 E. MAIN STREET CARNEGIE, PA 15106 (412) 429-7675 FACSIMILE (412) 429-7679 PAID #69006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC. v. TODD A JEWELL, ~o 07-~~,y e,~:~`r~I COMPLAINT IN CIVIL ACTION Filed on behalf of: LVNV FUNDING, LLC. Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 East Main Street Carnegie, PA 15106 (412) 429-7675 Plaintiff Defendant 2970.12240JEWELL, TODD.wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC. ) NO. Plaintiff ) v. ) TODD A JEWELL, ) 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 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 maybe 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 2 LIBERTY AVENUE CARLISLE, PA 17013 800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC. )) NO. D? ^ /P Tny Plaintiff ) v. ) TODD A JEWELL, ) Defendant ) COMPLAINT IN CIVIL ACTION C'~,L`7~ AND NOW, comes Plaintiff, LVNV FUNDING, LLC., above named, the purchaser and assignee of the obligation under suit, by and through its attorney, GREGG L. MORRIS, ESQUIRE and the law offices of PATENAUDE & FELIX, A.P.C and files the following Complaint in Civil Action, and in support thereof aver as follows: 1. Plaintiff, LVNV FUNDING, LLC, (hereinafter LVNV) is a limited partnership and, for purposes of this litigation, maintaining a place ofbusiness at 15 South Main Street, Greenville, SC 29601. 2. Defendant is TODD A JEWELL, an adult individual, believed to currently reside at 110 WESTGATE DR, MOUNT HOLLY SPRINGS, PA 17065. 3. Defendant(s) owes the sum of $25,132.42 for credit extended by BANK OF AMERICA to Defendant at account number 4356002505376960 . 4. Defendant(s) is in default for failing to make payments on the aforesaid account. 5. LVNV purchased and now owns the aforesaid account. A copy of an Affidavit from LVNV and the Bill of Sale or Assignment are collectively referred to and attached hereto as Plaintiff's Exhibit "A" and incorporated herein by reference. 6. Plaintiff has demanded payment but Defendant(s) has failed or otherwise refused to pay the aforesaid sum due. WHEREFORE, Plaintiff demands Judgment in its favor, and against Defendant(s), in the amount of $25,132.42 with continuing interest thereon at the legal rate from the date of Judgment plus costs. The aforesaid amount is within the jurisdictional amount for compulsory Arbitration. Respectfully Submitted: Patenaude & Felix, A.P.C Carnegie, YA 15106 (412) 429-7675 ~~ AFFIDAVIT ~~ State of South Carolina County of Greenville I, Steve Hawkins, being first duly sworn on oath, depose and state as follows: 1. I am an Authorized Representative of LVNV Funding LLC and I am duly authorized to make this Affidavit. 2. That account number 4356002505376960, Todd A Jewell, ("Account") is owned by LVNV Funding LLC 3. The Account was acquired by LVNV Funding LLC from its affiliate; Sherman Originator LLC. 4. Upon the acquisition of the Account from Sherman Originator LLC, all of Sherman Originator LLC's interest in the Account was vested in LVNV Funding LLC DATED this 18th day of April, 2006. ~~ Signature Subscribed and sworn to before me This 18th ay of April, 2006. ~~-,,_ Portfolio # 5019 Susan G. Argentieri Notary Public Statie of South Carolina . Comm. , d-15-2015 AfidMfx3 VERIFICATION AND NOW, Gregg L. Morns, verifies the statements made in this Complaint that are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of Pa.C.S. Section 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided by him by the Plaintiff. The verification of the party will be provided if requested. Date: Carnegie, PA 15106 (412) 429-7675 `~ ~. '\~ /~-' 1- 7 V `~ 7~ ~ na ~ ~ c~ - ~ -x, -~-, ~ ~ ~ .:~ nz~ r' ~ ~~ ~r: ~; == ~ ~;__, - ~ -r; Fi .~.> ~ C' ` " ~ L3 .._ ~ ~ Y t ~- .~ ~' i7 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC. ) NO. 2007-1894 Plaintiff ) v. ) TODD A JEWELL, ) Defendant ) PRAECIPE FOR STAY DUE TO BANKRUPTCY Filed on behalf of: LVNV Funding, L.L.C., Plaintiff Counsel of Record for This Party: Gregg L. Morris, Esquire Pa I.D. #69006 Patenaude & Felix, A.P.C. 213 East Main Street Carnegie, PA 15106 (412) 429-7675 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LVNV FUNDING LLC. ) NO. 2007-1894 Plaintiff ) v. ) TODD A JEWELL, ) Defendant ) PRAECIPE FOR STAY DUE TO BANKRUPTCY TO: Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Please stay proceedings in the matter captioned above due to Defendant's Petition for Bankruptcy filed at Docket No. 1-07-1448, filed in the Middle District of Pennsylvania. Thank you. Date: P~t~,fiaude &~'elix, A.P.C 213 E. Main Street Pittsburgh, PA 15106 (412) 429-7675 I, Gregg L. Morris, attorney for Plaintiff, LVNV Funding, L.L.C.,, hereby certify that a true and correct copy of foregoing document was served this date by ordinary mail upon the following: Michael S. Travis 3904 Trindle Rd Camp Hill, PA 1~0~ Date: & Felix, APC for Plaintiff 213 E. Main Street Carnegie, PA 15106 (412) 429-7675 LJ _ Q t ~ ~ ~_ ~ r V -r? ,s~ l~+ ~ (~ =Y ~ i t i ( i 1\j"'~`` _ ~__' (~~ f J - ~ a < ..~ ~ / 'f"_ `„""„~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-01894 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS JEWELL TODD A JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JEWELL TODD A the DEFENDANT at 2038:00 HOURS, on the 16th day of April 2007 at 110 WESTGATE DRIVE MT HOLLY SPRINGS, PA 17065 by handing to TODD A JEWELL a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.76 Affidavit .00 Surcharge 10.00 .00 `'~l~glb?C~„., ''~ 33.76 Sworn and Subscibed to before me this day of , So Answers: .. ._ ~...-r---_ R. Thomas Kline 04/17/2007 PATENAUDE & FELIX By. Dep t erl f A.D.