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Home My WebLink About08-4528Our File No.: 173140 -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. REBECCA A BAIR 3543 GREEN ST CAMP HILL, PA 17011-4319 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Qj q Six NOTICE el ?/I/ -li-M 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. REBECCA A BAIR 3543 GREEN ST CAMP HILL, PA 17011-4319 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OJF. YS-29 et&-.( 7211 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 REBECCA A BAIR, an adult individual residing at 3543 GREEN ST CAMP HILL, PA 17011-4319. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #5049948078422146; 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 $2,181.69. 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 $2,181.69 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS CIATES, P.C. Attorney f 2Deht A Law Firm Enaag d C Mectim BY: David J. Dated: 7/21/2008 Our File No.: 173140 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 undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworpt-Wsfication to authorities. David J. Al Attorney for DATE: 7/21/2008 REBECCA A BAIR 3543 GREEN ST CAMP HILL, PA 17011-4319 STATEMENT OF ACCOUNT LVNV FUNDING LLC Debtor's Name: REBECCA A BAIR Account Number: 5049948078422146 Original Creditor: SEARS Balance Due: $2,181.69 Our File No.: 173140 EXHIBIT "A" -Tl r- r ? F17 C --j CD ?? [TI Z SHERIFF'S RETURN - REGULAR CASE NO: 2008-04528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING INC VS BAIR REBECCA A MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BAIR REBECCA A the DEFENDANT , at 0019:50 HOURS, on the 11th day of August , 2008 at 3543 GREEN STREET CAMP HILL, PA 17011 KEITH BARR by handing to HUSBAND OF DEFENDANT 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 18.00 Service 13.00 Affidavit .00 Surcharge 10.00 .00 q'v:3? L )w 41.0 0 Sworn and Subscibed to before me this day So Answers: r R. Thomas Kline 08/13/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A.D. Our File No.: 173140 APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING LLC ) Plaintiff, ) vs. ) REBECCA A BAIR ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4528 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER A OCIATES, P.C. Attorn s f r Plaintiff A Law Firm En ag d in Debt Collection By: Kimberly F. Scian, Esquire Dated: February 4, 2009 D Ei f t a