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Home My WebLink About08-5319 Our File No.: 136977 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 CROWN ASSET MANAGEMENT, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. ANDREA S ORNER 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0% - 6319 Civik Terry. 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 r 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 CROWN ASSET MANAGEMENT, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. ANDREA S ORNER 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CROWN ASSET MANAGEMENT, LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are ANDREA S ORNER, an adult individual residing at 16 GLENWOOD DR B CAMP HILL, PA 17011-1138. 3. Plaintiff, CROWN ASSET MANAGEMENT, LLC, is the Assignee and Successor in Interest of Account #4418119101635718; and said account was issued to Defendant(s) by FIRST NATIONAL BANK OF OMAHA, 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 $10,316.29. 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 $10,316.29 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm En-aac RTES, P.C. Collection BY: David J. Apot r, Esquire Dated: 8/5/2008 Our File No.: 136977 f i VERIFICATION S V S A r-l S t7 V p w q- hereby states that I am 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, infoanation, and belief. 'The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4944 relating to unswom falsification to authorities. DATE: • Crown Fite Number Primary Debtor Name: Crown Asset Management, LLC Statement of Account Primary Debtor Home Address: Additional Debtor Name: Original Lender: Original Lender Account Number. Alternate Lender Account Number. Account Open Date: Original Lender Charge-off Date: Date of Last Payment to Original Lender. Date of Last Payment to Crown Asset Management, LLC: Account Purchase Date by Crown Asset Management, LLC: Principal Balance Due: Interest Amount Due: Total Amount Due: 402611 ORNER. ANDREA S 16 GLENWOOD DR B CAMP HILL, PA 17011 First National Bank of Omaha 4418119101635718 4418119101635718 11/01/2002 11/29/2005 03/28/2005 06/26/2007 $ 9,862.35 $ 0.00 $ 9,862.35 NOTE: Crown Asset Management, LLC created this statement using data provided by the original creditor or prior owners of the account and does not intend to imply that the originating creditor participated in the creation of this statement. 55 Printed: 11/16/2007 PA23 oo ?. a c7 -? W ? cn -? c , •- ter f ,.7 `?? SHERIFF'S RETURN - REGULAR CASE NO: 2008-05319 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CROWN ASSET MANAGEMENT LLC VS ORNER ANDREA S STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon nVNTWV ANMPPA c the DEFENDANT , at 1250:00 HOURS, on the 15th day of September, 2008 at 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 by handing to ANDREA ORNER 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 15.00 Affidavit .00 Surcharge 10.00 .00 /c/63/0Y 3.00 4 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 09/15/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff A. D. 4ft Our File No.: 136977 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CROWN ASSET MANAGEMENT, LLC Plaintiff, VS. ANDREA S ORNER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5319 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, ANDREA S ORNER, in the default of an Answer, in the amount of $10,773.47 computed as follows: Amount claimed in complaint: $10,316.29 Amount Paid: - $(0.00) Interest from August 05, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $457.18 Costs $0.00 Attorney fees $0.00 TOTAL $10,773.47 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, ANDREA S ORNER, last know address is 16 GLENWOOD DR B CAMP HILL, PA 17011-1138. APOTHAKER & Attorney A Law Firm Eng t By: David J. TES, P.C. Debt Collection Dated: 5/14/2009 ' A OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: ANDREA S ORNER 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 CROWN ASSET MANAGEMENT, ) LLC ) Plaintiff, ) vs. ) ANDREA S ORNER ) Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5319 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. Anothaker, Esc at this telephone number: 215-634-8920 Our File No.: 136977 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 CROWN ASSET MANAGEMENT, LLC Plaintiff, vs. ANDREA S ORNER Defendant. Civil Action AFFIDAVIT OF NON-NULITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5319 : 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 16 GLENWOOD DR B CAMP HILL, PA 17011-1138. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defen*t(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defense indicated that the Defendant(s) is/are not in the military. David J. Aipothaker Attorney f Plaintiff Data 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. Department ofDefinse Manpower Data Centw Fury Storms R;epart Pursuant as the Servieemembers Civil Rd dAct MAY-14-2009 09 39.20 QRNER ANDRFA S Based an the kfixmistion you have T edL the DhWC does not possess my idwastim :drat &e idvid el is cu mm* on active duty. Upon searching the iefCrtne-- dda'batmlcs of the Dement of Demme Maupower Data Center, based an the iafomralion thst you provided, the above is the conestt stutusoftbe kdvidod to all branches of the Mlilary. 4101V Marl' M. Snffvety: Down. D"cluc Department ofDefense - Manpower Data Center 1600 Wilson Blvd, Sake 400 A&pgton, VA 22209-2593 Mw DcAmse ManpoPwa Data Outa (DMA is an a on of dw Dgmtment offI se"inaintsins due Defense Earobr s>t and HiSW Reporting System, (DEERS) database *" is the olficiel source of daft on fly for oiftary me" care and other c%W systems. Die Department of Demme shy snpparb the edement of the Servir eanesnbers Civil ReWAct 150 USCS Apex. §§ 501 et seql:(SCRA) pbna* fhe SMe& and SA x& +t1 Relief Act of 1940}_ DUDC has issued ham of 6onsimils of-does not possess any i&zmshon indicong t the kd n&wl g curready an active daW responses. and has ezpaimeed a smed error rate_ In the event the k div dual retermeed above, or any firmly merbar, Mend. or r+clrr ive assns in nap manner that the indA+ida d is an active dory, or is odmv is a eadded to the protections of the SCRA, you are skan* awomvpd to obtain forthar man of the pasoa's active duty std by conuc* tint p ersods Mary Service via day Idefi mse rd" URL provided below. Nyon have evidence the person is an active-duty and you dd to obtain this Bonet Il a Service vra$caeon, ins of the S+CRA may be invoked ago mst you. Wyou obtrk further information about the person ( e.g., an SSN, kq*aved accuracy of DOB, a mid& aurae), you can shit your request agoin at this Web site and we w panide a new date liar AM gwyry 'This response redctts current active duty stag only. Farms kmation, please contact dw UMary Service SCR A pomts- of-coataeL Seer bMx l mw - ?C09SLDR.html WARNDWk This cert&sk was provided based an a amnia and So cisl Securer number (SSN> provi&d by ae regaesux. erg an erroneous name or SSN will came an envacous cat cute to be provided R*pwrf,ZD:FP TMCXtr 136977 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CROWN ASSET MANAGEMENT, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) ANDREA S ORNER ) NO. 08-5319 To: ANDREA S ORNER 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 20, 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 DAVI OTHAKER, 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 * CASE NO: 2008-05319 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CROWN ASSET MANAGEMENT LLC VS ORNER ANDREA S S (' 2 3 08 STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ORNER ANDREA S the DEFENDANT at 1250:00 HOURS, on the 15th day of September, 2008 at 16 GLENWOOD DR B CAMP HILL, PA 17011-1138 ANDREA ORNER by handing to 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 15.00 Affidavit .00 Surcharge 10.00 .00 43.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 09/15/2008 APOTRAKER & ASSOCIATES By: Deputy Sheriff A. D. OF F" 2CCQ R'io"V20 A11 10: L? 6"` I aj e?- a3vs /6 12 2-Z S- 3 Il. W iLc- en.-LiLCL Our File No.: 136977 APOTHAKER & ASSOCIATES, P.C. BY: Benjamin J. Cavallaro, Esquire Attorney I.D.# 307949 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff CROWN ASSET MANAGEMENT, LLC Plaintiff, vs. ANDREA S ORNER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08-5319 ASSIGNMENT OF JUDGMENT c~ t°" ~-' c_'. ,~ -~ ; ._..; z ~ ° --;; r :_.. ~, ~; cn ~, ~ v ~ c-; ~ --_ ~ c~ w c:, ~ ~- '~~ 3 • ~ CSI AND NOW COMES Benjamin J. Cavallaro, Esquire, Attorney for Plaintiff in the within matter, and hereby provides the following in support of an assignment of judgment: 1. Plaintiff obtained Judgment against Defendant in the sum of $10,773.47 on or about May 20, 2009. 2. Defendant made $0.00 in payments towards the judgment since the judgment date. 3. Plaintiff is the judgment creditor of record. 4. The last address of record for the judgment debtor(s) is 1550b Old Trail Rd Etters, Pa 17319. 5. Plaintiff hereby transfers and assigns all title rights and interest in the within judgment to the following: MIDLAND FUNDING, LLC 8875 AERO DRIVE SUITE 200 SAN DIEGO, CA 92123 6. Plaintiff hereby authorizes MIDLAND FUNDING, LLC to recover, compromise, settle and enforce the within judgment. Plaintiff hereby withdraws all rights and claims to the within judgment. ~q ~ ppg77-~ ~~f~a~7 ~~'aa~9y APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: Benjami .Cava Taro, Esquire Our File No.: 136977 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorneys for Plaintiff CROWN ASSET MANAGEMENT, LLC Plaintiff vs. ANDREA S ORNER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ NO.: 08-5319 Civil Action CERTIFICATION OF SERVICE I, Benjamin J. Cavallaro, Esquire, attorney for Plaintiff, certify that on November 13, 2012, I caused to be served a copy of the Assignment for Judgment by mail on: ANDREA S ORNER 1550B OLD TRAIL RD ETTERS, PA 17319 APOTIJAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: Benjami J. Cava faro, Esquire ~~L ®~ sal Crown /asset' Nlar€agement, LLC.("Seller"), for value received _and purstunt to.. the tei-rns and conditions of Account 1'r.ir~chase Agreement ("Agreerttettt"), dated as of December 23, Z01 1, liet`w-een Seller alid Midland Funding LLC ("Buyer"), does hereby sell, assign and convey to Buyer; its successor and ass%.gns, all right title and interest of Seller in. and to: those Accounts described in the Agreerritnt in ~Iie Final Aecoiints File; without recourse and without representati.ar€s of or warranty of; collectability; or atlrerwise, excej~t to the extent provided far within. the.Agreerrzent_ Far the gurpase of-this .&.rtI_t of Sale, the Final Accounts File datz s1~a11 b"e December 22, ZOI l . Unless oth'erivrse defined herein-; all capitalized terms appearing in this Bill of Sale sha[1 have the meanings de-fined forsueh ter-izis in t1~e Agreetne"nt_ Seller represents atzei. Fvarraztts Shat; to Seller's .krtovvledge, all of the infoi-tnation contained in the Due Diligence Accounts Fi-le, the G.hairt of Title _F.ile and the 1~inaI Accounts. File (collecti~=eIy "~e11er's A.ccot€tat Infbrrnation"): (a) constitutes Se.ltet's own. business .r~eords re-gard~tng the Accounts, together with the unadulterated electronic records of all Original 1,enders and Ft'eviorss Sellers regarding the Accounts ~vl~ich Seller. robed upon. artd incorporated into its business eeeor-cts regarding the .Accounts; and (b). acct€ratel}< tef(ects in .a11 material respects the iriforrnatiort in Sellet~'s database. The Acccrurtt irxformafiari in Seller's Account lnfoimation was 4~~:pt in the regular= course of Seller's. f~tisincss.. The Accot_trtt" informaticx~ in Seller's Account lnfot-Ination vas made or comp-fled at or near the= ~srne of tLie event and t'aCOrded by '(or from irlfortzration transmitted by) a person (i) with kt-iovvledge"of dle data entered. into and.zrraintained in Selle`r's database, or (ii)' wlta caused fEte data~to~ be entered inCO.and maintained in Seller's database. It .is tI~e .regular practice of Sellers business to rrtair~itain and coin~ile -such data. T'o the best of Seller's knowledge and bel"ief it i~vas also the r=egular practice: of the Original Lenders. and Pre~riaus Sellers to maintain anal compile such data. EXECUTED this .~g~ da}% of:December, 20l l . CROWN ASSET 1~~1AIVAGEiv1E`I~TT, LL,G -Brian ~iTfiams, C)/O 1vfIDLAN FUND LI;C ~y: Name.: J' . r'andon Black Title: P esideri~ A~prov~d by Lec~af