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Home My WebLink About07-6662t.. Our File No.,: 98530 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.6.08423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff LVNV FUNDING, LLC c/o Apothaker & Associates, P.C 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: LT7 - 1D(o(D a C i v i l term 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 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 P APOTHAK .R & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417, Welsh'Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff LVNV FUNDING, LLC c/o Apothaker & Associates, P.C 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 7- (GG 2 ? I-14,, - CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, LVNV FUNDING, LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is LEANDER A LEDEBOHM, an adult individual residing at 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $9,803.33. 8. , Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is BANK OF AMERICA. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $9,803.33 plus costs, and reasonable attorney's fees. APOTHAKER & ASSOCIATES, P.C. Attorney f Plaintiff A Law Firm Ena ed Debt Collectioi BY: David Dated: 10/23/2007 Our File No.: 98530 VERIFICATION David J. Apothaker, Esc hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to u4 M falsification to authorities. David ?Apothaker kttorne or Plaintiff DATE: 10/23/2007 r LVNV FUNDING, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 STATEMENT OF ACCOUNT Debtor's Name: LEANDER A LEDEBOHM Account Number: 4427115000524945 Original Creditor: BANK OF AMERICA Balance Due: $9,803.33 Our File No.: 98530 EXHIBIT "A" A? 8 n r9l it r w 00 V Q-, 1 "1 -5 Fn (CA SHERIFF'S RETURN - REGULAR CASE NO: 2007-06662 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS LEDEBOHM LEANDER A WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEDEBOHM LEANDER A the DEFENDANT , at 1943:00 HOURS, on the 8th day of November-, 2007 at 5214 DEERFIELD AVENUE MECHANICSBURG, PA 17050-6824 by handing to RANDY 13LUMANSTOCK ADULT IN CHARGE 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 Service Affidavit Surcharge Sworn and Subscibed to before me this So Answers: 18.00 11.52 .00 J! 10.00 R. Thomas Kline .00 39.52 11/13/2007 APOTHAKER & ASSOCIATES By: _ day Deputy Sheriff of A. D. I? Our File No.: 98530 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 LVNV FUNDING, LLC ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) VS. ) NO.: 07-6662 LEANDER A LEDEBOHM ) Civil Action Defendant. ) PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, LVNV FUNDING, LLC and against Defendant, LEANDER A LEDEBOHM, for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon the defendants on November 08, 2007 by the CUMBERLAND Sheriff's Department. Copies of the proofs of service are attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on January 8, 2008 and also attached hereto. Assess damages in the amount of (a) Balance: (b) Interest from October 23, 2007 (c) Costs TOTAL APOTHAKER & Attorney A Law Firm Enda4 By: David 1, $9,803.33 $162.76 $118.02 $10,084.11 iOCIATES, P.C. Plaintiff n Debt Collection Dated: 2/1/2008 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 LVNV FUNDING, LLC Plaintiff, VS. LEANDER A LEDEBOHM Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-6662 Civil Action NOTICE Pursuant to Rule 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. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 a?r4?og r? APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff LVNV FUNDING, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs. LEANDER A LEDEBOHM NO.: 07-6662 Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the inquiry indicated that the Defendant(s) is/are not i Manpower Data Center has sent back our David J. Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. CASE NO: 2007-06662 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS LEDEBOHM LEANDER A WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEDEBOHM LEANDER A the DEFENDANT , at 1943:00 HOURS, on the 8th day of November , 2007 at 5214 DEERFIELD AVENUE MECHANICSBURG, PA 17050-6824 by handing to RANDY BLUMANSTOCK, ADULT IN CHARGE 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 11.52 Affidavit .00 Surcharge 10.00 .00 39.52 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 11/13/2007 APOTHAKER & ASSOCIATES By: f.-? Deputy Sheriff A. D. Our File No.: 98530 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff, vs. LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 07-6662 NOTICE OF INTENTION TO TAKE DEFAULT TO: LEANDER A LEDEBOHM DATE OF NOTICE: January08, 2008 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 against you. Unless you act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 151 DAVID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 FEB-01-2008 10:33:53 < Last Name First/Middle Begin Date Active Duty Status Service/Agency LEDEBOHM LEANDER A Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 14. y6t lot Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 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 is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htip://www.defenselink.mil/ WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/1/2008 0 -TI O G -- M D - ? -rr IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLVANIA LVNV Funding, LLC Leander A Ledebohm Plaintiff, vs. Defendant(s). Case No. 07-6662 Civil Action SUGGESTION OF BANKRUPTCY COMES NOW the Defendant, Leander A. Ledebohm, through his undersigned attorney, and would show the Court: 1. He has filed a petition for relief under Title 11, United States Code, in the United States Bankruptcy Court for the Middle District of Pennsylvania, which bears the case number 1:08-bk- 00755. 2. Relief was ordered on March 4, 2008. 3. This action is founded on a claim from which a discharge would be a release or that seeks to impose a charge on the property of the estate. 4. This is for informational purposes only, and does not constitute a notice of appearance by the undersigned. WHEREFORE, the defendant suggests that this action has been stayed by the operation of 11 U.S.C. § 362. /s/ Kimberly A. Coleman Kimberly A. Coleman IT IS HEREBY CERTIFIED that a copy of the foregoing Suggestion of Bankruptcy was delivered by mail to LVNV Funding, LLC, this April 2, 2008. /s/ Kimberly A. Coleman Kimberly A. Coleman Software Copyright (c) 1996-2007 Best Case Solutions, Inc. - Evanston, IL - (800) 492-8037 Best Case Bankruptcy APOTHAKER & ASSOCIATES, P.C. 24.17 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 Our File No.: 98530 LVNV FUNDING, LLC VS. Plaintiff, LEANDER A LEDEBOHM Defendant. TO: LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA 17050-6824 DEAR MR. LEDEBOHM: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-6662 Civil Action INTERROGATORIES Judgment has been entered against you in the Court of Common Pleas, CUMBERLAND County, on February 19, 2008 in the amount of $10,084.11 and taxed cost of suit remains due and unpaid. Attached is a list of 12 interrogatories that Court Rules require you to answer within thirty (30) days from the date you receive this. If you do not answer the attached questions within the time required, the opposing party may file a Motion to Order the Court to impose punishment for contempt. . You must answer each question, giving complete answers, and attach additional pages if necessary. False or misleading answers may subject you to punishment by the Court. However, you need not provide information concerning the income and assets of others living in your household unless you have a financial interest in the assets or income. Be sure to sign and date your answers and return them to the address in the upper left hand corner within thirty (30) days. Dated: 3/7/2008 APOTHAKER Attorney for Pl. A Law Firm Er. TES, PC in Debt Collection David J. Apothaker ZV i ? ?