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Home My WebLink About08-40504 Our File No.: 170307 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. TINA ASKINS 631 GATES LN ENOLA, PA 17025-1610 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY oy- 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. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 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. TINA ASKINS 631 GATES IN ENOLA, PA 17025-1610 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6f- YO!D &w,? 2- 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 TINA ASKINS, an adult individual residing at 631 GATES IN ENOLA, PA 17025-1610. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #4447961111398182; and said account was issued to Defendant(s) by CREDIT ONE BANK N.A., 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 $1,413.24. 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 $1,413.24 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaai BY: Dated: 7/1/2008 ATES, P.C. bt David Jk Apothaker Our File No.: 170307 1 VERIFICATION David J. Apothaker, Esa. 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., o authorities. DATE: 7/1/2008 L,aviu i. tipumaicer Attorney for Plaintiff TINA ASKINS 631 GATES LN ENOLA, PA 17025-1610 STATEMENT OF ACCOUNT LVNV FUNDING LLC Debtor's Name: TINA ASKINS Account Number: 4447961111398182 Original Creditor: CREDIT ONE BANK N.A. Balance Due: $1,413.24 Our File No.: 170307 EXHIBIT "A" '?JJ h ?a c O 0 ? -Val .. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04050 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS ASKINS TINA KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ASKINS TINA the DEFENDANT at 631 GATES LN at 0012:43 HOURS, on the 12th day of July , 2008 ENOLA, PA 17025-1610 TINA ASKINS DEFENDANT by handing to 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 Service Affidavit Surcharge )llz,/Oi (- So Answers: 18.00 15.00 .00 r 10.00 R. Thomas Kline .00 43.00 07/14/2008 APOTHAKER & ASSOC Sworn and Subscibed to By: before me this day of A.D. 1 ? Our File No.: 170307 - ' 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. TINA ASKINS Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-04050 Civil Action PRAEC1 PE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, TINA ASKINS, in the default of an Answer, in the amount of $1,475.85 computed as follows: Amount claimed in complaint: $1,413.24 Amount Paid: - $(0.00) Interest from July 01, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $62.61 Costs $0.00 Attorney fees $0.00 TOTAL $1,475.85 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, TINA ASKINS, last know address is APOTHAKER & AS ( Attorneys fo la A Law Firm Eneae in I: By: David J. GATES LN ENOLA, PA 17025-1610. P.C. Collection Dated: 5/14/2009 TO: TINA ASKINS 631 GATES LN ENOLA, PA 17025-1610 LVNV FUNDING LLC Plaintiff, VS. TINA ASKINS Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-04050 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, Esc at this telephone number: 215-634-8920 SflQf°J Our File No.: 170307 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 Plaintiff, vs. TINA ASKINS 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 631 GATES IN ENOLA, PA 17025-1610. We inquired with the web site of the Defens power Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if De ndant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Def rise power Da enter has sent back our inquiry indicated that the Defendant(s) is/are not in the mili David J. Apothaker Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-04050 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. Dept of Ddwse Ma power Baia Center Mikay Stains Report Pursuant to the Sesv ce?aezre bexs CH Relie#`Ad MAY-14-2009 09--43.49 Hoed on the won you have Jarmahed, the DMDC dices not possess any irfatmation imficating that the sdieridsat is correctly an active dety - Upon sag dw infatuation dda banks of the Department of Die Alsopow er Datai Center, basest en the inEamudan tint you provided, the aloe is the current swus ofthe infiwidad as to A brands of *e Merry. Mary M- anv* Dvwk Director Department of Defense - Manpower Data Center 1600 Whm , Suite 400 A& gtoea, VA 22209-2593 Mw Deiemse Manpower Data Cemer (DM)C) is an eqpokation of the Dexfftn eot cif Def a dud asaiatai ns, the Defense Emallment and E iiity Reporting System (DEERS) database vAich is the *&W source ofdsta as eligity for military medical ere and other oily systems. The D aespt of De6r c straggly suppatts the enf arc dment of the Serv?icrmaanberss 0 d Act {50 USCS Axm §§ 581 et wql (SCRA) Qbnaedy the Serf & and Saiiats' Cid ROWAct of 1940). DWDC bean a ned bawkeds cf thousands of'does not possm any information iediicating'that the abdividind is csmcady on active dad" des. and has eapxiesced a smel error rate. In the event the idnidud rf c+ed above, or coy faatiy? amber, Mead. or represemmive asserts in any miatmer fist the individual is on arch a duty, or is otherwise eked to the prolections of the SCRA, you we st on* encouraged to obtain fizdm ved6cadon of the person's active duty by cog pe rsas MrYt ery Service via the'el disk mir URL provided below. Myou bane evidence the person is an active-day and you fw to obtain thin addi iocW Adliltary Service vedficatim provinons, of the SCRA may be invoked against yep. Kyou obtain fxdw infixmation Awat the parson (e.g., an SSN. improved wxwacy of DOH, a middle name), you can submit your request again at this Web ske and we wi l provide a new cartilinft far that qwy. This respaose reflects current active +dtay status only. For piewe comma the Miftary Service SrCRA points- cf-cootact. Sec. hats-. , ST.llR hmal WARNMtr. This caftTcarte was provided based on a name and Social S ? noad r (SSN) provided by the rewester. Provieling an wooeous name or SSN will cause an envaccus certificate to be provided. rrm' 170307 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) TINA ASKINS ) NO. 08-04050 To: TINA ASKINS 631 GATES LN ENOLA, PA 17025-1610 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 12, 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 D I J. 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 S'HERIFF'S RETURN - REGULAR CASE NO: 2008-04050 P COUNTY COMMOWEALCUMBERTH : AU LVNV FUNDING LLC ( j JUL 17 2008 J VS ASKINS TINA KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsyluania, who being duly sworn according to law, says, the within COMPLAINT.& NOTICE was served upon ASKINS TINA the DEFENDANT at 0012:43 HOURS, on.the 12th day of July 2008 at 631 GATES IN ENOLA, PA 17025-1610 by handing to TINA ASKINS DEFENDANT 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 15.00 Affidavit .00 Surcharge 10.00 .00 43.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 07/14/2008 APOTHAKER & ASSOC By: of A. D. fL.{..iJ 2G99 HAY 19 PH 5: 5 u ,oiK.ov ?CL- A, R-4i ?.2saL6