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Home My WebLink About08-4113Our File No.: 15 9401 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. STEVEN M MILLER 330 4TH ST ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D S- q ll3 ,N11 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. 40 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. ) STEVEN M MILLER ) ) 330 4TH ST ) ENOLA, PA 17025 Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p ?- y 3 c f, 1 4 ciiu- 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 STEVEN M MILLER, an adult individual residing at 330 4TH ST ENOLA, PA 17025. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #4427100039383984; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $8,801.48. 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 $8,801.48 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for?intiff A Law Firm Engage m ebt Collection BY: David J. Dated: 7/2/2008 Our File No.: 159401 VERIFICATION David J. A othaker Es q. 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 understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 7/2/2008 LVNV FUNDING, LLC STEVEN M MILLER 330 4TH ST ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 159401 STEVEN M MILLER 4427100039383984 BANK OF AMERICA $8,801.48 EXHIBIT "A" 1 1. J J V b b C) c? cr7 ,. rn- r C.TF O I SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04113 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LVNV FUNDING LLC VS MILLER STEVEN M R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT MILLER STEVEN M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , MILLER STEVEN M 330 4TH ST NOT FOUND , as to WEST FAIRVIEW, PA 17025 PER MOTHER, MOVED TO HARRISBURG OVER A YEAR AGO. Sheriff's Costs: So answers Docketing 18.00 °-? Service 15.00 ?J Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 48.00 APOTHAKER & ASSOCIATES 07/31/2008 Sworn and Subscribed to before me this day of , A.D. Our File No.: 159401 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. STEVEN M MILLER 330 4TH ST ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY n o NO.: gR- N 3 4e6w =' T- r? nib C.-P ' c Z - . cl _ gm 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 10 .h4v-24 T Yl' aI 0R tof a f. h z :Z d 01 1fir Hoz ?? _FY • 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. STEVEN M MILLER 330 4TH ST ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 6W'y y1) 3 ????1 qur+- 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 STEVEN M MILLER, an adult individual residing at 330 4TH ST ENOLA, PA 17025. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #4427100039383984; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $8,801.48. 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 $8,801.48 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney foq tiff A Law Firm Engage$ in ebt Collection BY: David J. Dated: 7/2/2008 Our File No.: 159401 w VERIFICATION David J. A othaker Es g. 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 subject to the penalties of 18 Pa.C.S.A. 4904 relating to understands that the statements therein are made falsification to authorities. David J. Apothaker Attorney for Plaintiff DATE: 7/2/2008 r LVNV FUNDING, LLC STEVEN M MILLER 330 4TH ST ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: STEVEN M MILLER Account Number: 4427100039383984 Original Creditor: BANK OF AMERICA Balance Due: $8,801.48 Our File No.: 159401 EXHIBIT "A" ;?-;. ., =?I _,?? -, ...w .5.. ?, 9 ??.???r?? ' /'' \} r `??v ?`?P u?ti? r Our File No.: 159401 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff, VS. STEVEN M MILLER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4113 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS IATES, P.C. Attorneys f Pl 'ntiff A Law Firm Enaas in ebt Collection By: David J. ApothaRtr, Esquire Dated: 10/24/2008 t a ? is °? n c rs a , :r 1 r~= Ln: C..? '? C