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Home My WebLink About08-3476Our File No.: 1603 87 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. ROBERT HANES 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070-2218 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6$ - 3q 7(v NOTICE 1. 6 I+efM 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 pag?nas 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 1NMEDIATAMENTE. 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. ROBERT HANES 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070-2218 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: op - 34z 6 Ct'?J 72- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are ROBERT HANES, an adult individual residing at 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070-2218. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #5121071804279465; and said account was issued to Defendant(s) by SEARS, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $15,095.21. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $15,095.21 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law SECOND COUNT 8. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #7981923391768241; and said account was issued to Defendant(s) by LOWES, the Original creditor. 9. Defendant received, accepted and used the account to its benefit. 10. This account is in default and Defendant(s) has an unpaid balance of $2,255.54. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "B. 11. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "B". 12. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,255.54 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $17,350.75 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law APOTHAKER & SOCIATES, P.C. Attorney o Plaintiff A Law Firm Ena a in Debt Collection BY: Dated: 5/30/2008 David Our File No.: 160387 VERIFICATION David J. Apothaker, 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 falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 5/30/2008 ! Y LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 ROBERT HANES 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070-2218 STATEMENT OF ACCOUNT Debtor's Name: ROBERT HANES Account Number: 5121071804279465 Original Creditor: SEARS Balance Due: $15,095.21 Our File No.: 160387 EXHIBIT "A" LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 ROBERT HANES 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070-2218 STATEMENT OF ACCOUNT Debtor's Name: ROBERT HANES Account Number: 7981923391768241 Original Creditor: LOWES Balance Due: $2,255.54 Our File No.: 160517 EXHIBIT "B" m 72- r Ui = ? J SHERIFF'S RETURN - REGULAR CASE NO: 2008-03476 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS HANES ROBERT SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT Sr NOTICE was served upon HANES ROBERT the DEFENDANT , at 0844:00 HOURS, on the 14th day of June , 2008 at 1727 WEATHERBURN DR NEW CUMBERLAND, PA 17070 ROBERT HANES by handing to 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 &h FID 8 , ? Sworn and Subscibed to before me this So Answers: 18.00 17.00 _ .00 a 10.00 R. Thomas Kline .00 45.00 06/16/2008 APOTHAKER & AS ATE o By: day eputy Sheriff of A. D. Our file No.: 1603 87 & 160517 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff Attorney ID# 55140 LVNV FUNDING LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. ROBERT HANES Defendant DOCKET NO.: 08-3476 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on July 22, 2008, STIPULATED by and between Plaintiff, LVNV FUNDING LLC, and Defendant, ROBERT HANES, parties as follows: 1. Defendant agrees to pay the sum of $17,350.75, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid shall be paid by Defendant, ROBERT HANES, to the attorneys for Plaintiff in the following manner: a. Payments of $250.00 to be paid on or before the 3e of every month, starting July 31, 2008, until balance is paid in full All checks are to made payable to LVNV FUNDING LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, ROBERT HANES, fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff must notify Defendant's attorney, MICHAEL S. TRAVIS, ESQUIRE, in writing of Defendant, ROBERT HANES's default. The name of Defendant's attorney and address that notice will be sent is: MICHAEL S TRAVIS, ATTORNEY AT LAW Michael S. Travis, Esquire 3904 Trindle Road Camp Hill, PA 17011 4. If the default is not cured within 15 days after receipt of written notice to the Defendant's attorney, the Plaintiff has the right to obtain entry of Judgment against Defendant, ROBERT HANES, ex parte, in the sum of $17,350.75, giving Defendant, ROBERT HANES, credit for all sums actually paid pursuant to the terms of this Stipulation. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: ? -1 Kimbe y F. cian, Esquire By: ROBERT IBS c""; rv F... ? ? ti`.:J _ ?_ J _ CJ f'7 ? ""„? _ N ' G'7 il ?. ? ?? ??..' -> ?^;.-. i ?! J? .if. C?7 ,„ T Our File No.: 160387 APOTHAKER & ASSOCIATES, P.C. 2013 SEp By: David J. Apothaker 17 Rlf 1. Attorney I.D.# 38423 MBERL�14tJ 520 Fellowship R ad C306 PEN�sYLVANJgt� T Y 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 08-3476 ROBERT HANES ) Civil Action Defendant ) PRAECIPE TO ENTER JUDGMENT PURSUANT TO STIPULATION TO THE PROTHONOTARY: Please enter a judgment in favor of plaintiff, LVNV FUNDING LLC, and against Defendant, ROBERT HANES, for failure to comply with the terms and conditions of the Stipulation in Lieu of Judgment (Stipulation), filed with this Court on August 4, 2008, a copy of which is attached hereto as Exhibit "A". Assess damages in the amount of. Balance: $ 17,350.75 Less: Payments: ( 8,500.00) TOTAL $ 8,850.75 — a z David J. Apotha sq. Attorney for Plain iff C�. a1s7 �$ �� L' *,PA Our File No.: 160387 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 COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 08-3476 ROBERT HANES ) Civil Action Defendant ) David J. Apothaker, Esquire, certifies as follows: 1. I am an attorney with the Law Firm of Apothaker & Associates, P.C., attorneys for the Plaintiff in the above captioned matter, and as such, have full and complete knowledge of the facts herein. 2. The matter was settled by and between the parties by Stipulation in Lieu of Judgment (Stipulation), on August 4, 2008, a copy of the Stipulation is attached hereto and marked as Exhibit "A". 3. Defendant breached this agreement by failing to make payments in accordance with the terms of said Stipulation. 4. Therefore, pursuant to the Stipulation, Plaintiff is proceeding towards the entry of Judgment in the amount of$14,350.75, giving the Defendant credit for payments made totaling $8,500.00, for a total of$8,850.75. I verify that the statements made in this Certificatio true and correct. I understand that false statements herein are made subject to the pena ies of 8 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apoth e , sq. Attorney for Plai 'ff r OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ROBERT HANES 349 OLD STAGE RD LEWISBERRY, PA 17339 COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 08-3476 ROBERT HANES ) Civil Action Defendant ) 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. JUDGMENT FOR FAILURE TO COMPLY WITH THE TERMS AND CONDITIONS OF THE STIPULATION IN LIEU OF JUDGMENT JUDGMENT BY DEFAULT ❑ JUDGMENT IN REPLEVIN 074 ❑ JUDGMENT BY CONFESSION ❑ JUDGMENT FOR POSSESSION ❑ JUDGMENT ON AWARD OF ARBITRATORS 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.: 160387 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 COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 08-3476 ROBERT HANES ) 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 am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 349 OLD STAGE RD LEWISBERRY, PA 17339. 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 Defen oemil ower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in ry. Da vid J. ApotI Attorney for lamti — I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 54904, relating to unsworn falsification to authorities. r .Department of Defense Manpower Data Center Results as of:Aug-26-2013 04:12:06 SCRA 3.0 Statim Report Pursuant to Service.members (Civil Relief Act. Last Name: HANES First Name: ROBERT Middle Name: Active Duty Status As Of: Aug-26-2013 On Active Duly On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA _ No.-,i,, NA This response reflects the i-ndii-victuals'active tlury status based on the Active Duty S_tatus Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA ti a 'NA t r° a No n NA i This response reflects where�the individual left active duly status within 367 days preceding the Active Duty Status Date The Member or His[Her Unit Was Notified of a future Call-Up to Active Duty on Active Outy Status Date Order Notification Start Date Order Notification End Date Status Service Component NA �iNA - -� d "No ° NA This response reflects whether the indivi0uat or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Ylial A 4w4 4��_ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)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 DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as 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 only 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 was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 64F9Y074P08ASD0 j Our file No.: 16 387 & 160517 APOTI TAKER ASSOCIATES,P.C. °_ z, A110 �- 7 200 r 65 u T 2417 Welsh Road, Suite Z1 9520 UU Philadelphia,PA 19114 - (215)634-8920 18.y Attorneys for Pl ntiff , Attorney ID#55140 COURT OF COMMON PLEAS LVNV FUND G LLC } CUMBERLAND COUNTY Plaintiff, } DOCKET NO.: 083476 '! vs. ROBERT HAN3 S ) Civil Action } STIPULATION IN LIEU OF JUDGMENT Defendant ) } i The matters and things in controversy having been discussed by and between the parties, and a stWement having been agreed upon: It is o i July 22, 2008, STIPULATED by and between Plaintiff, LVNV FUNDING LL , and Defendant,ROBERT HANES, parties as follows: 1.. Defendant agrees to pay the sum of$17,350.75, which sum Plaintiff agrees to accept in full s ttlement of its claim herein, inclusive of counsel fees and court costs. 2. 1be sum aforesaid shall be paid by Defendant, ROBERT HANES, to the attorneys for Plaintiff in the following manner: i. Payments of$250.00 to be paid on or before the 301i of every month, starting July 31,2008,until balance is paid in full I checks are to made payable to LVNV FUNDING LLC, and sent to: Apothaker&Associates,P.C. 520 Fellowship Road C306 Mount-Laurel,NJ 08054 3. In tie event Defendant,ROBERT HANES,fails to pay in accordance with the terms set forth in this Stipulation,then; and in that event,Plaintiff must notify Defendant's at orney,MIC14AEL S. TRAVIS,ESQUIRE, in.writing of Defendant, ROBERT S's default. Tt e name of Defendant's attorney and address that notice will be sent is: l i} 3 S m � MICHAEL S TRAVIS,ATTORNEY AT LAW Michael S. Travis,Esquire 3904 Trindle Road Camp Hill,PA 170111 4. if he default is not cured within 15.days after.receipt of written notice to the Defendant's anorneyl the Pla,nfffhas the right to obtain entry of Judgment against Defendant,RO'E ERT HANES, ex paste,in the sum of$17,350.75,giving Defendant, ROBERT HAN..-S, credit for all sums actually:paid pursuant to the terms of:this Stipulation. We hereby consent t6 the form,and entry of the within Stipulation. APOTHAKER&ASSOCIATES,P.C. r Attorneys for Plaintiff A Law Firm Engaged in Debt Ccillection jy KtnbIAS c ian,Esquire ROBERT S 1 A ter 9. x f <f 1 f Y • wn i • C c d Our file No.: 160387& 160517 ,✓ ! 5 `�► (� �° APOTHAKER ASSOCIATES,P.C. 2417 Welsh Road, suite 21 #520 AUG " 7 Philadelphia,P 19114 (215)634-8920 Bye x Iz Pn Attorneys for Pl, 'ntiff z 4 W 0 Attorney ID##551.40 COURT OF COMMON PLEAS LVNV FUND 4G LLC ) CUMBERLAND COUNTY i Plaintiff, ) DOCKET NO.: 08-3476 vs. ) ROBERT RAN ES ) Civil Action STIPULATION IN.LIEU OF JUDGMENT .Defendant ) The matters and things in controversy having been discussed by and between.the parties,and a,settlement having been agreed upon: It is orl July 22; 2008, STIPULATED by and between. Plaintiff, LVNV FUNDING LLC,and Defendant,ROBERT HANES,parties as follows: 1. Defe dant agrees to pay the sum of$17,350.75, which sum Plaintiff agrees to accept in full s 'dement of its claim herein,inclusive of counsel fees and court costs. 2. �he sum aforesaid shall be paid by Defendant, ROBERT HANES, to the attorneys for P aintiff in.the following manner: a. Payments of$250.00 to be paid on or before the 3&of every month, starting.July 31,.2008,until balance is paid in full All checks are to made payable to LVNV FUNDING LLC, and sent to. Apothaker& Associates,P.C. 520 Fellowship Road C306 Mount Laurel,NJ 08054 3. Ibn t e event Defendant,ROBERT HANES,fails to pay in accordance with the terms set forth in this Stipulation,then, and in that event,Plaintiff must notify 'Defendant's a orney,MICHAEL TRAVIS,ESQUIRE, in writing of Defendant, ROBERT RAI MS;'s default. I I Thle name of Defendant's attorney and address that notice will be sent is: k k MICHAEL S TRAVIS, ATTORNEY AT LAW r. Michael S. Travis,Esquire 3904 Trindle Road Camp Hill,PA 17011 4. If he default is not cured within 15 days after receipt of written notice to the Defendant's attorney,the Plaintiff has the right to obtain entry of Judgment against Defendant;ROBERT HANES, ex parte,in the sum of$17,350.75, giving Defendant, ROBERT HANES, credit for all sums actually paid pursuant to the terms of this Stipulation. We herel y consent to the form and entry of the within Stipulation. APOTHAKER&ASSOCIATES,P.C. Attorneys for Plaintiff A.Law Firm Engaged in Debt Collection _.. Kirribe y F.5'cian,Esquire By: t ROBERT.. �S 1 3 i 1 1 � 4 f ). i'. k E