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Home My WebLink About08-4053Our- File No.: 170215 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. MICHAEL T STRAHOSKY 1040 WAYNE AVE CARLISLE, PA 17013-1639 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 AP6THAKER & 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY MICHAEL T STRAHOSKY 1040 WAYNE AVE CARLISLE, PA 17013-1639 Defendant. NO.: d F- IL/05 3 C i 4; t.l '74Z -, 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 MICHAEL T STRAHOSKY, an adult individual residing at 1040 WAYNE AVE CARLISLE, PA 17013-1639. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #0558883393537; 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 $1,511.38. 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 A- WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of l $1,511.38 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engagodin Debt Collection BY: Dated: 7/l/2008 Our File No.: 170215 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 fication to authorities. subject to the penalties of 18 Pa.C.S.A. 4904 relating Lpothaker DaviAttorney fo r Plaintiff DATE: 7/l/2008 LVNV FUNDING LLC MICHAEL T STRAHOSKY 1040 WAYNE AVE CARLISLE, PA 17013-1639 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL T STRAHOSKY Account Number: 0558883393537 Original Creditor: SEARS Balance Due: $1,511.38 Our File No.: 170215 EXHIBIT "A" 0 LJ rra r; -e cJ?, SHERIFF'S RETURN - REGULAR CASE NO: 2008-04053 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS STRAHOSKY MICHAEL T DENNIS FRY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon STRAHOSKY MICHAEL T the DEFENDANT at 0010:14 HOURS, on the 12th day of July , 2008 at 1040 WAYNE AVE CARLISLE, PA 17013-1639 MARY ANN STRAHOSKY by handing to MOTHER OF 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: So Answers: Docketing Service 18.00 5.00 Affidavit 00 Surcharge 10.00 R. Thomas Kline 00 33.00 07/14/2008 APOTHAKER & ASSOC Sworn and Subscibed to By: before me this day eputy S r f of A.D. Our File No.ti 1702 15 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. MICHAEL T STRAHOSKY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4053 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MICHAEL T STRAHOSKY, in the default of an Answer, in the amount of $1,578.41 computed as follows: Amount claimed in complaint: $1,511.38 Amount Paid: - $(0.00) Interest from July 01, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $67.03 Costs $0.00 Attorney fees $0.00 TOTAL $1,578.41 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, MICHAEL T STRAHOSKY, last know address is 1040 WAYNE AVE CARLISLE, PA 17013-1639. A Law By: Dated: 5/14/2009 ASSOCIATES, P.C. for Plaintiff red in Debt Collection . ApoulaKer OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: MICHAEL T STRAHOSKY 1040 WAYNE AVE CARLISLE, PA 17013-1639 LVNV FUNDING LLC Plaintiff, VS. MICHAEL T STRAHOSKY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4053 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 sfiQfo? Our File No.: 170215 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. MICHAEL T STRAHOSKY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4053 Civil Action AFFIDAVIT OF NON-ARLITARY 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 1040 WAYNE AVE CARLISLE, PA 17013-1639. We inquired with the web site of the Defens anpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if efendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Def se anpow Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in the mili 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. Department of Defame Manpower Data Center Mkury Stabs Rat Frrsnaot to the Srrviceo Cis Act AtIv May hi Sam*-Dkm Director Dqmdmat ofDdense - Manpower Data Center 1640 ikon Blvd.. Sake 4014 ArPr oon, VA 22209-2593 MAY-14-2# 49 0941-48 The Defense Mafia Data Center 03AMDC) is an org an of the Depariaseot afDefme that maitains the Defemse Enrolment and ElgW Reporticg;Sy A= (DEERS) database which s the oifcid source of data on a llgW for nalitery medical care and odur clip lAky systems_ Ilse Department of ?ewe strawy sopports the edamensest of the Steen Civil RAWAct 5 USCS Alm& §§ 501 et seq] (SCRA) (formerly the Sates' and Sahara' CH Relief Act of 1940)_ DMDC has hmed hundreds offiansands of "does not possess any inilicaiiing d w the indlividlad ai euvra* ion active daffy" responses, and has rgxdesced a =A e not rate. In the eveai the indrvidnat referenced above, at my fimiy su ember. Ricad, at vwese to live asserts iu any aaannax that the i d'rvi lod is an amine daaty, or is otherwise eased to 8e prolectionis of the SC RA, you we strmgly encouraged to obtain fadw valicatir of the ms's active duty status by codactiug dmt perscxa's Mary Save ce via *e'ddrsselink mir URL `pwvs&d below. if you have evidence the person on active-qty and you fa to obtain this additional wry Sege va oa, provisions of the SC RA may be invoiced aging yea Ryon obtain further irsformndon about dre person ( e.g., an SSN, improved accuracy of DDB, a m dcge nmae}, you a submit Yom request again at Ibis Web site and we wit provide a new cerrtilica t fat that query. "This response reelects earresd active duty status orziy. For historical afiamintion, please contact the Mtwy Service SCRA poiats- af-c, ci- See: hEh jhvww. g R.l" WARNNCr. T'lis cexti fate was provided based on a name and Sock Security number (SSlytj provided by the rem. Providing an arroneous name or SSN wi cause an erroneous ceetificate to be provided. tMlBtMa*'p Upon searching the Ofixasahm data?banb o ffic Deparbuent of Demme boaopow!er Data Ceuta:. based an due mfi mabm that you providLed, the above is the com ent status of the ina rAud as to at bra m*n of the Ammy. • 170215 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) VS. ) MICHAEL T STRAHOSKY ) To: MICHAEL T STRAHOSKY 1040 WAYNE AVE CARLISLE, PA 17013-1639 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4053 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 DA APOTHAKER, ESQUIRE APOT R & 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 . 0 SHERIFF'S RE'T'URN - REGULAR CASE NO: 2008-04053 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS STRAHOSKY MICHAEL 'T f( ? r I3? JUL 17 2008 DENNIS FRY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being 'duly sworn according to law, says, the within COMPLAINT ,& NOTICE was served upon STRAHOSKY MICHAEL T the DEFENDANT at 0010:14 HOURS, on the 12th day of July 2008 at 1040 WAYNE AVE CARLISLE, PA 17013-1539 by handing to MARY ANN STRAHOSKY MOTHER OF 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 5.00 Affidavit .00 Surcharge 10.00 .00 33.00 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 07/14/2008 APOTHAKER & ASSOC By: e456puty 5 r f A. D. FILET - _-;r;c nF THE-, ' , , -,TARY s 20,199 M Y! 9 PN ?: 0 6 GG N ly ?Al. as -?zL P4 ?.K 13 qA