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Home My WebLink About08-1001A. 4& Our File No.: 144182 APOTHAKER & 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. CINDY L CROMER 177 QUARRY HILL RD SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q$- Tool Nit -Fetm 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 provisions 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 4 APOTHAKER & ASSOCIATES, P.C. Y 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. CINDY L CROMER 177 QUARRY HILL RD SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: G' 8 - /6z) 1 04, r ,Q -7 , 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 CINDY L CROMER, an adult individual residing at 177 QUARRY HILL RD SHIPPENSBURG, PA 17257. 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 $1,939.93. . 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is KMART. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,939.93 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for?tiff A Law Firm Engaged in ebt C ectiol BY: Dated: 1/29/2008 David J. Our File No.: 144182 VERIFICATION David J. Anothaker, Esq. 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 unsworn falsification to authorities. 1 David K Apothaker Attorney for Plaintiff DATE: 1/29/2008 LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 CINDY L CROMER 177 QUARRY HILL RD SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: CINDY L CROMER Account Number: 7101584000237004 Original Creditor: KMART Balance Due: $1,939.93 Our File No.: 144182 EXHIBIT "A" ? iq- P :- '" ? 110 -n l ' t r ? t t71 = V rT 00 ? SHERIFF'S RETURN - REGULAR CASE NO: 2008-01001 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS CROMER CINDY L STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROMER CINDY L the DEFENDANT , at 1935:00 HOURS, on the 15th day of February-, 2008 at 177 QUARRY HILL ROAD SHIPPENSBURG, PA 17257 by handing to CINDY CROMER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.52 Affidavit .00 Surcharge 10.00 00 a/?15/D P 3 9. 5 2 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 02/19/2008 APOTHAKER & ASSOCIATES By: De uty Sheriff of A. D. Our File No.: 144182 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 LVN V FUNDING LLC Plaintiff, vs. CINDY L CROMER Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1001 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, CINDY L CROMER, in the default of an $2,053.95 computed as follows: Amount claimed in complaint: $1,939.93 Amount Paid: - $(0.00) Interest from January 29, 2008 to 06/18/09 at the legal interest rate of 6.000 per annum $114.02 Costs $0.00 Attorney fees $0.00 TOTAL $2,053.95 I hereby certify that the appropriate Notices of Default, as attached have been mai Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, CINDY L CROMER, last know address is 177 QUARRY HILL RD PA 17257. Dated: 6/18/2009 APOTHAKER & ASSOCIATES, P.C. Attorneys f prjaintiff A Law Firm Enaa d Debt Collection By: David , in the amount of in accordance with URG, Our File No.: 144182 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. CINDY L CROMER NO.: 08-1001 Civil Action Defendant. 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 Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 177 Q1 SHIPPENSBURG, PA 17257. We inquired with the web site of the Defense Manpower Data Center, to Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any br, Mary M. Snavely-Dixon, Director of the Defense M o er Data Center has sent indicated that the Defendant(s) is/are not in the military. David J. o Attorney f Plaintiff The above signed understands that the statements herein are made subject to the pena Section 4904 relating to unswom falsification to authorities. m the attorney for ARRY HILL RD i at 1600 Wilson of the military. our inquiry ties of 18 Pa. C.S. Department of Defense Manpower Data Center Military Status Report Pursuant to the Senicemernbers Ciro Relief Act <. Last FirsvMiddle Begin Date Name Active Duty Status T1- _15-200911;0204 CRONTER CINDY L Based on the information you have funnisbed, the D?1DC does not possess indicating that the individual is currently on active duty, Upon searching the information data barks of the Department of Defense Manpower Data Center, based you prodded, the above is the current status of the ia&idual as to all branches of the Military. A U wt fit. 44ft?_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 tb'iilson Blvd, State 400 .Arlington, VA 22209=2593 The Defense Manpower Data Center (D:4LDC) is an organization of the Department of Defense that Enrollment and Eligibly Reporting System (DEERS) database which is the official source of data on care and other e}igibki systems. l% supports the enforcement of the Senicemeriibers Civil Relief Act [50' The Department of Defense strong et seq] (SCRA) (formerly the Soldiers' and Sailors' Cis RelidAct of 1940)_ DMDC has issued hundreds not possess any information indicating that the individual is current,, on active duty" responses, and has erp rate. In the event the in& idual referenced above, or any family member; friend or representative asserts in individual is on active duty. or is otherwise entitled to the protections of the SCRA_ you are strongly encour verification of the per°son's active duty, status by contacting that persons Military Service via time "defeuselinl below- If you have e%idence the person is on active-duty and you fag to obtain this additional M&m Ser i provisions of the SCRA may be invoked against you. If you obtain f n-ther information about the person (e.g., an SSN, improved accuracy of DOB, a middle your request agar 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 of-contact. See: htt?°tN,,;siv.defenselink rmlfaq is-PC09SLDR.html WARNTIIlG; This certificate was provided based on a nine and Social Security number (SS 17) prodded Providing an erroneous name or SSA rs l cause an erroneous certificate to be proyided ?/Agenc, information the information that the Defense for military medical ;CS Appx_ §§ 501 thousands of "does enced a small error Ly mariner that the ed to obtain finther ail" LM proNided verification- you can submit SCA points- the requester. At Port1D:BUC-4GECPCIti 144182 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) CINDY L CROMER ) NO. 08-1001 i To: CINDY L CROMER 177 QUARRY HILL RD SHIPPENSBURG, PA 17257 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: April 23, 2008 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARIN 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 FOR H BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT TvIAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 DAN/14 J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collectio 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR CASE NO: 2008-01001 P COMMONWEAT= OF PENNSYLVANIA : COUNTY OF CUMBERLAND LVNV FUNDING LLC DEFENDANT , at 1935:00 HOURS, on the 15th day of Fe at 177 QUARRY HILL ROAD SHIPPENSBURG, PA 17257 by handing to CINDY CROMER VS CROMER CINDY L STEPHEN BENDER Sheriff or Deputy Sheriff o Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CROMER CINDY L _ the a true and attested copy of COMPLAINT & NOTICE 2008 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 11.52 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 39.52 02/19/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Sheriff of , A.D. y1jv. oo ?C. Q4 -791 AV C6C--k 13q 'R-A C20119-09 4 TO: CINDY L CROMER 177 QUARRY HILL RD SHIPPENSBURG, PA 17257 LVNV FUNDING LLC vs. CINDY L CROMER Plaintiff, Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1 NO.: 08-1001 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 ARBITRA 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, Essq. at this telephone number: 215-634-8920 /-S/ eu.4- P, &r??, o,, ??c4s?o 9