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Home My WebLink About08-5320V Our File No.: 178163 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. HARRY GANDY 55 CAVALRY RD CARLISLE, PA 17013-1602 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: a$ - 53a0 &V A len%,% 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 Our File No.: 178163 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. HARRY GANDY 55 CAVALRY RD CARLISLE, PA 17013-1602 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., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are HARRY GANDY, an adult individual residing at 55 CAVALRY RD CARLISLE, PA 17013-1602. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #0362051048712; 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 $2,432.55. 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 $2,432.55 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &?KSPOCIATES, P.C. A Law Firm Endged in BY: Dated: 8/28/2008 David J. Apoth#ker, Esquire Our File No.: 178163 VERIFICATION David J. A,pothaker, 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 rel g t unworn falsification to authorities. David J. A?Wiaker, Esquire Attorney for Plaintiff DATE: 8/28/2008 LVNV FUNDING LLC HARRY GANDY 55 CAVALRY RD CARLISLE, PA 17013-1602 STATEMENT OF ACCOUNT Debtor's Name: HARRY GANDY Account Number: 0362051048712 Original Creditor: SEARS Balance Due: $2,432.55 Our File No.: 178163 EXHIBIT "A" p ' ? ? Y f"•fj 'f _ CD SHERIFF'S RETURN - NOT FOUND 41 CASE NO: 2008-05320 P C6MMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LVNV FUNDING LLC VS GANDY HARRY 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 GANDY HARRY but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT I 55 CAVALRY ROAD , GANDY HARRY NOT FOUND , as to CARLISLE, PA 17013-1602 DEFENDANT IS DECEASED. Sheriff's Costs: Docketing Service Not Found Surcharge )Elog09, C)I..v So answer 18.00 5.00 5.00 R. Th as Kline 10.00 Sheriff of Cumberland County .00 38.00 APOTHAKER & ASSOCIATES 09/15/2008 Sworn and Subscribed to before me this day of A. D. Our File No.: 178163 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. ) HARRY GANDY ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-5320 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys r laintiff A Law Firm Enga ed In Debt Collection By: David J. Apothaker, Esquire Dated: 10/8/2008 t L rn y