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Home My WebLink About08-5199'Oar FiTe No.: 168685 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. KONRAD J MITTEREDER 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 68 - 5199 Civil lelrwt 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 ';kPOT11AKER & 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. KONRAD J MITTEREDER 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 KONRAD J MITTEREDER, an adult individual residing at 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #A2009080381082; and said account was issued to Defendant(s) by CITIFINANCIAL, INC, 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 $6,490.06. 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. '` I WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $6,490.06 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for tiff A Law Firm Engage in ebt Cctioi BY: David J. Apothaker, Esquire Dated: 8/19/2008 Our File No.: 168685 a V 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 relagi(g tc unworn falsification to authorities. David J. A othaker, Esquire AttorneyTtw- Plaintiff DATE: 8/19/2008 KONRAD J MITTEREDER 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065 STATEMENT OF ACCOUNT LVNV FUNDING, LLC Debtor's Name: KONRAD J MITTEREDER Account Number: A2009080381082 Original Creditor: CITIFINANCIAL, INC Balance Due: $6,490.06 Our File No.: 168685 EXHIBIT "A" r 406 C7 c a « rJ of _ € :? " rj r rr SHERIFF'S RETURN - REGULAR CASE NO: 2008-05199 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS MITTEREDER KONRAD J SGT. DAVID ZEIGLER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MITTEREDER KONRAD J was served upon DEFENDANT the at 0906:00 HOURS, on the 8th day of September, 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 KONRAD J MITTEREDER 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: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 .00 Q111104 n!, 33.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/09/2008 APOTHAKER & ASSOCIATES By : Deputy Sheriff A.D. Ouro?ile No.: 168685 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. KONRAD J MITTEREDER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5199 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KONRAD J MITTEREDER, in the default of an Answer, in the amount of $6,945.91 computed as follows: Amount claimed in complaint: $ 6,490.06 Less: Amount Paid: ( 0.00) Plus: Interest from August 19, 2008 to August 12, 2009 at the legal interest rate of 6.00% per annum 344.35 Attorney fees 0.00 TOTAL $ 6,945.91 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, KONRAD J MITTEREDER, last known address is 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065. APOTHAKER ASS CIA Attorn e s for ainti A Law Firm Ena aed i Debt By: David J. Apothaker Dated: August 12, 2009 AW a % Ours ile No.: 168685 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, KONRAD J MITTEREDER vs. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5199 Civil Action Defendant. AFFIDAVIT OF NON-MILITARY 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 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Center has sent back our inquiry 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. if APOTHAKER&ASSOCIATES, P.C. ATTORNEYS AT LAW Department of Defense Manpower Data Geer Status Report Pursuant to t Service members Civil Relief Act AUG-12-2009 08:23:42 Last Name Fie Bed Date Alive Doty Stataa ServicelAsency V71TEREDER KONRAD 7 Based on dk- infonna ion you have frunished,. the D-N,,= does not possess any idormation indicating that the idaal is currently on active duty. ? s Upon searching the iefarmation data banks of the Department of Defense Manpower Data Center, based on the information that you provided,. the abo%a is the current status: of the i idkial as to all branches of the Air. Allu 14 Mary M. Snavely-Dixon. Director Department of Defense - Manpower Data Cramer 1600 %%on Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Cater (D_MDQ is an organ of *e Dement of Defense that maintains the Dd6m Eraodmeat and Eligibility Reporting System (DEERS) database which is the dial source of data on efigibFity fbr military medical care and ether elilpW systems. The Department of Defense strongly supports the enforcement of the Sw6cemembers Cif Re lief'Act [50 USCS Apex, §§ 501 et seq (SCRA) (formerly the Sobers' and Sailors' Civil RelidAct of 1940)_ DIM+ff C has issued hundreds of'thousands of *does not possess any iufonwatim indicating fiat the xidi ttal is currently to active daW responses, and has wed a sail error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any mater that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain firrther veri6cat on ofthe gersork active dray status 1 contacting that person's NGitary Service via t "defensefirkmr URL provided below- If you have evidence the person is on active-Duffy and you fad to obtain this additional ?M ry Service verification, provisions of the SCRA may be invoked against you. If you obtain fixthe r ' ' about the person ( e.g., an SSN, i Woved accuracy of DOB, a middle name), you can submit your request again at this Web sae and we w proves a now c atii+cate for dw query. This response reflects current active duty status only. For historical infionnation, please contact the Military Service SCRA points- of contact, See= '?a y?r.def tPC09SLDR_html WARNING: This certificate was provided based an a name and Social Security number (S SN) provided by the requester.. Pronging an aroneous name or SSN will cause an erroneous cett Ve to be pry Report ID CADC} UMNY 215 634.8920 215 634.8421f 1W 168685 LVNV FUNDING, LLC VS. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY KONRAD J MITTEREDER To: KONRAD J MITTEREDER 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-5199 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 08, 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 I J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR C'ASE' NO: 2008-05199 j? Or COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AVNV FUNDING LLC VS MITTEREDER KONRAD J SGT. DAVID ZEIGLER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MITTEREDER KONRAD J the DEFENDANT , at 0906:00 HOURS, on the 8th day of September, 2008 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to KONRAD J MITTEREDER 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 5.00 Affidavit .00 Surcharge 10.00 .00 _ 33.00 Sworn and Subscibed to before me this day of r So Answers: R. Thomas Kline 09/09/2008 APOTHAKER & ASSOCIATES By: s Deputy Sheriff A.D. OF TNT F-anti ??TQR?i' 2009 AUG 20 AM 6: 09 CLUE ?i lNf), FE- rXr 'ff 'dh'a l $14. 00 P a ATW GC,* 14 16 580 eT* aa9479 IJoke?, i.?a.J.? I OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KONRAD J MITTEREDER 32 CENTER ST LOT 25 MT HOLLY SPRINGS, PA 17065 LVNV FUNDING, LLC ) Plaintiff, ) VS. ) KONRAD J MITTEREDER ) Defendant. ) NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5199 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgme t 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 eNo/o9