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Home My WebLink About08-2746Our File No.: 153786 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 KNAUB 372 OLD MILL RD CARLISLE, PA 17015-8915 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: M - a'14(o Civa Tirm 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 provisioner 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 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 KNAUB 372 OLD MILL RD CARLISLE, PA 17015-8915 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O F- .2 7 V6 ?1 T. - - 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 KNAUB, an adult individual residing at 372 OLD MILL RD CARLISLE, PA 17015-8915. 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 $1,862.60. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is CITI-SEARS. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,862.60 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Atto "y or Plaintiff A Law Firm E ed in Debt Collection BY: Dated: 4/10/2008 . Apothaker Our File No.: 153786 VERIFICATION David J. Apothaker, EN. 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 unworn falsification to authorities. DATE: 4/10/2008 Attorney for Plaintiff CINDY L KNAUB 372 OLD MILL RD CARLISLE, PA 17015-8915 STATEMENT OF ACCOUNT LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Debtor's Name: CINDY L KNAUB Account Number: 5484092938712 Original Creditor: CITI-SEARS Balance Due: $1,862.60 Our File No.: 153786 EXHIBIT "A" oo L y^r ? - yy SHERIFF'S RETURN - REGULAR CASE NO: 2008-02746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS KNAUB CINDY L WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE KNAUB CINDY L DEFENDANT the , at 1000:00 HOURS, on the 17th day of May , 2008 at 372 OLD MITT, R(AT) CARLISLE, PA 17015 by handing to CHARISSA PUTT, ADULT IN CHARGE 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 6.00 Affidavit .00 Surcharge 10.00 00 5,E 3 4. 0 0 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 05/19/2008 APOTHAKER & ASSOCIATES By: i - V /,- eputy Sheriff was served upon of A. D. 7 Our File No.: 153786 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 LVNV FUNDING LLC Plaintiff, VS. CINDY L KNAUB Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2746 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, CINDY L KNAUB, in the default of an Answer, in the amount of $1,964.64 computed as follows: Amount claimed in complaint: $1,862.60 Amount Paid: - $(0.00) Interest from April 10, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $102.04 Costs $0.00 Attorney fees $0.00 TOTAL $1,964.64 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, CINDY L KNAUB, last know address is 372 OLD MILL RD CARLISLE, PA 17015- 8915. APOTHAKER & A IATES, P.C. Attorneys f r Pl ' tiff A Law Firm Engag in ebt Collection By: David J. Apothaker Dated: 5/14/2009 TO: CINDY L KNAUB 372 OLD MILL RD CARLISLE, PA 17015-8915 LVNV FUNDING LLC Plaintiff, vs. CINDY L KNAUB Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-2746 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 Our File No.: 153786 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 VS. CINDY L KNAUB COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, NO.: 08-2746 Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. 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 372 OLD MILL RD CARLISLE, PA 17015-8915. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon,, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Attorney r Data Center, located at 1600 Wilson s) is/are in any branch of the military. has sent back our inquiry 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. Department ofD mse Manpower Data Ceow Mliduy Status Repast Pursuant to the Setvic s CA ReliefAct MAY-14-2009 09:18:19 Upon wwdwg the ink ando n databanks of the Department of Defense Manpower Data Center, based an the i n6mu ticn that you provided, the above is the current status of the individual as to all branches of the may. A01 w it Mary M. Saar: Dbwa, Director Deportment of Defense - Manpower Data Center 1600 Wilson Mvd, SWe 400 Arlington, VA 22209-2593 The Defense Mampowa Data Center (MM is an oc r of dw. D ent of Defi=c dw maiatainks the Def me Enrollment and E &y Reporting System (DEERS) database which is the official source of data on a ty for 1tary medical care and other elig y systems. The Department of Ddense sego ngty supports the eefrrrcement of fire Servicemesrabers Civil Relief Act [54 USCS ApM §§ 501 et seq) (SCRA) fcnwdy the Soldiers! and Sailors' CM RefdA.ct of 19413)_ DMDC bays issued kodreds oftbousaards of "does not possess my ofamuhn indicaning tbat the amfividnal a eurre an active AW req ae ses, and bas wed a srnNJI errar rate. In the event the individtail, raferenced above, or arty family member, friend, or v4mentafive asserts in any mermtr dot the individual is an alive daty. or is otherwise entitled to the prates of the SCRA, you we swan* encouraged to obtain frrrdw vetcation cftbe person's active duty status by contacting dug persona"s h1litary Service via the "defimselink mr URL provided below. M you have evidence the :person is an active-may and you fait to obtain this additional 141ftwy Service vim, proms of Ilse SCRA may be invoiced against you. If you ova fuether° rdaraation about the person (e.g.. an SSN, bVroved accuracy of DUB, a m dole name] you can submit your request again at this Web site and we wili provide a new certilcate for did query. i s response reiiects current active duty status only. For bistoirical ` ifinwhon. Please contact true Artery Service SCRA points- cam. Scr.hwyhvww WARI`l'INCr Ibis eerlilicate was provided based on a rye and Social Security ra r {SSM presided by Ilse rewesw. Providing an erroneous name or SS"3 wili cause an errtmem ce rt1icate to be provided. Report.ID°$31 1' TeNO KMUB CINDY L Based on the rots you have finisbed. the I7.MDC does not posses s any in rmaa ion indicating that the individual is curready an active duty. 153786 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) CINDY L KNAUB ) NO. 08-2746 To: CINDY L KNAUB 372 OLD MILL RD CARLISLE, PA 17015-8915 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 18, 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 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DA . APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC 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 + SHERIFF'S RETURN - REGULAR t CASE CIO'- 2008-02746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS KNAUB CINDY L 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 KNAUB CINDY L the DEFENDANT at 1000:00 HOURS, on the 17th day of May , 2008 at 372 OLD MILL ROAD CARLISLE, PA 17015 by handing to CHARISSA PUTT, ADULT IN CHARGE 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 6.00 Affidavit .00 Surcharge 10.00 .00 34.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 05/19/2008 APOTHAKER & ASSOCIATES By: eputy Sheriff A. D. r FILED -(D OF THE - TRY 2ti5 9 MAY 19 Pi$I !, • 17 fTy g iw.od?i cL Ag? CK J ? 3y?77q ?? 2 537s a k?>tl tz, tr'W L?t