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Home My WebLink About08-50641w Our File No.: 166379 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. BARBARA KUHN 100 GORDON DR LOT 3 CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 69 -S61, I C?I'U , - L (-? 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 ,w APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. BARBARA KUHN 100 GORDON DR LOT 3 CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ,S"a & V C ?t/At 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 BARBARA KUHN, an adult individual residing at 100 GORDON DR LOT 3 CARLISLE, PA 17013. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #0181601100342092; and said account was issued to Defendant(s) by HSBC BANK BRUENERS/GOODS FRNTR, 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 $4,117.42. 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 $4,117.42 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorn r Plaintiff A Law Firm En in Debt Collection BY: David J. Aiaker, Esquire Dated: 8/12/2008 Our File No.: 166379 VERIFICATION David J. Apothaker, Esquire 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 relatiCt unworn falsification to authorities. David J. Ap ,jl , Attorney for Plainti DATE: 8/12/2008 BARBARA KUHN 100 GORDON DR LOT 3 CARLISLE, PA 17013 STATEMENT OF ACCOUNT LVNV FUNDING, LLC Debtor's Name: BARBARA KUHN Account Number: 0181601100342092 Original Creditor: HSBC BANK BRUENERS/GOODS FRNTR Balance Due: $4,117.42 Our File No.: 166379 EXHIBIT "A" rz? V -b. D 0 C f t-? i s N G"3 !V N V-C. 1 J '?J SHERIFF'S RETURN - REGULAR CASE NO: 2008-05064 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS KUHN BARBARA BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KUHN BARBARA the DEFENDANT , at 1040:00 HOURS, on the 6th day of September, 2008 at 100 GORDON DR CARLISLE, PA 17013 STANLEY HORN, HUSBAND LOT 3 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: So Answers: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 91d+lb233.00 09/08/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: AQ before me this day Deputy Sheriff of A.D. Our file No.: 166379 l 2 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 LVNV FUNDING, LLC ) Plaintiff, ) VS. ) BARBARA KUHN ) Defendant. ) OCT 14 2008 ?lUd COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-5064 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 October 03, 2008, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, BARBARA KUHN parties as follows: 1. Defendant agrees to pay the sum of $4,266.84, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $4,266.84 shall be paid by the by Defendant, BARBARA KUHN, to the attorneys for Plaintiff in the following manner: a. $150.00 to be paid on or before October 6, 2008; b. $250.00 to be paid on or before October 31, 2008; C. $100.00 to be paid on or before the 30'h day of each month, beginning November 30, 2008 until 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 fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $4,266.84, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to BARBARA KUHN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in De ollection By: Kimberly F. Sci squire j BARB ??? .?? {'? ?? '-? ?-,? --?+ --'# iii{.?. ??? --fin, ?.. _ . P _:r _ ? C` David D. Bueff Prothonotary Kirks. Sohonage, ESQ, Solicitor q4nee X Simpson 151 Deputy Prothonotary Irene E. Morrow 2nd Deputy Prothonotary Office of the Prothonotary Cum6erfand County, 1Pennsy(vania 68 "50(oy CIVILTERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 25TH DAY OF OCTOBER, 2011, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P 230.2 BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, P,4 17013 e (717 240-6195 0 Tax (717 240-6573