The URL can be used to link to this page

Home My WebLink About08-5346Our File No.: 178306 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. MEGAN SULLIVAN 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 03 5:M(p NOTICE a-lvi l (e - t 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.: 178306 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. MEGAN SULLIVAN 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495 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 MEGAN SULLIVAN, an adult individual residing at 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #6008890857934319; and said account was issued to Defendant(s) by JC PENNEY, 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 $2,189.40. 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 $2,189.40 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Eniza? BY: Dated: 9/2/2008 RTES, P.C. in Debt David J. ApothAer, Esquire Our File No.: 178306 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 made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unsworn falsification to authorities. David J. Ap6thaker, Esquire Attorne for Plaintiff DATE: 9/2/2008 MEGAN SULLIVAN 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495 STATEMENT OF ACCOUNT LVNV FUNDING LLC Debtor's Name: MEGAN SULLIVAN Account Number: 6008890857934319 Original Creditor: JC PENNEY Balance Due: $2,189.40 Our File No.: 178306 EXHIBIT "A" }Li v j 7 CI r O co . ; / - l QD < SHERIFF'S RETURN - REGULAR CASE NO: 2008-05346 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS SULLIVAN MEGAN KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SULLIVAN MEGAN the DEFENDANT , at 1600:00 HOURS, on the 16th day of September, 2008 at 2228 GLEIM COURT ENOLA, PA 17025-1495 MEGAN SULLIVAN 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 Service Affidavit Surcharge iGfD110 18.00 14.00 .00 10.00 .00 i?42.00 So Answers: Sworn and Subscibed to before me this day of , R. Thomas Kline 09/17/2008 APOTHAKER & ASSOCIATES -D"/ ",;/ /? By: A. D. Our File No.: 178306 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 3 8423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 LVNV FUNDING LLC Plaintiff, VS. MEGAN SULLIVAN Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5346 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, MEGAN SULLIVAN, in the default of an Answer, in the amount of $2,217.64 computed as follows: Amount claimed in complaint: $2,189.40 Amount Paid: - $(0.00) Interest from September 02, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $78.24 Costs $0.00 Attorney fees $0.00 TOTAL $2,217.64 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, MEGAN SULLIVAN, last know address is 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495. APOTHAKE & SATES, P.C. Atto eys or Plai tiff A Law Firm E ga ed in D Collection By: David J. Apothaker Dated: 5/14/2009 - i TO: MEGAN SULLIVAN 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495 LVNV FUNDING LLC Plaintiff, VS. MEGAN SULLIVAN Defendant. NOTICE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-5346 Civil Action 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. Apothaker, Esq_ at this telephone number: 215-634-8920 S1001o1F Our File No.: 178306 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 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. NO.: 08-5346 MEGAN SULLIVAN Defendant. Civil Action 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 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if they Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Attorney Data Center, located at 1600 Wilson 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. Deparmment of Defense Manpower Data Canter Mbary Status Deport Parsnaat to ffie Servscemembers Civil Relief Act MAY-14-2009 0+8:11 SULLIVAN MEGAN Based on dre inkmati n you have ft d. the DM£DC does not possess any zfofmation imficating chat the imlividmal is commily on active duty. Upon searching the io€Ormation data banks cfthe Department of IDcelmse Manpower Data Ceuta. based an the i on dust you pr'o'vided, the above is the comes of due individual as to A branches of Ox Day. 410 Mary M. Sm.,* Dhon. Director Deperitment of Defense - Manpower Data Center 1600 Wilson E hod., Sark 400 Ali, VA 22209-25993 The Defense Manpower Data Ceuta (MAX) is an aganiuatim of dw Depaa at ofDel a that mainta ims. dw Defense Elk and E *i1ity Repcxtog System (DEERS) datubase which is the vfficad source of&& on eIVW for naitmy amical care and odxr AqW systems. The Departrams of D e ? sappa w dce ednrcemrnt of &e'-%P ara ear ns CivI ReWAet [50 USCS A?ppz §§ 501 et seq] (SCRA) (Fam es y dre Sd&e& and Sailors' Ovil ReWAct of D ) _ DMA has nswedboadieds of dwossuds of 'does not possess any iefnametian indicating 'danthe indimIdualis taer on ewe duty" responses, and has end aE stod errar rate In the event the imbidaat refireaced above, or eny homily ate, Mead at representative asserts in any manner dint the k&vidad is an active duty, or is odierwise entitled to the protecdow of die SCRA, you are skan* encouraged to obtain father vedka6w of the person's active duty status by caatactig that persons AMkwy Service Ails the "dam usi!" URL provided below. If you have evidence the person is an active-duty and you fail to obtain dis additional wry Service caiion. provisions of the SCRA ny be in asked against you. M you obtain dodder nfatmation about dre p (e g., an SSN. improved accuracy of DOB, a as dcde }, you can submit your request again at this Wets site and we w'B prate aR new certificate for that query. Ibis response redccts current active duty status ody. For cal won, pose contact dfe Mary Service SCRA points- of-contact. Sae. h WARNINCr carti1icatc was provided band on a statne and Social Secu iLy Wirer (SSN) provided by due mpeswr Providing an «=aneauxs nacre or SSN well came an erroneous certificate to be provided. Rat -TMOVWC4K 178306 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. } MEGAN SULLIVAN ) NO. 08-5346 To: MEGAN SULLIVAN 2228 GLEIM CT APT 11 ENOLA, PA 17025-1495 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: October 23, 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 D 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 4CASE NO: 2008-05346 P SHERIFFS RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS SULLIVAN MEGAN SEP 3 0 2008 KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland'County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SULL I VAN 'MEGAN the DEFENDANT at 1600:00 HOURS, on the 16th day of September, 2008 at 222`8 GLEIM COURT ENOLA, PA 17025-1495 by handing to MEGAN SULLIVAN 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 14.00 Affidavit .00 Surcharge 10.00 .00 42.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 09/17/2008 APOTHAKE?' & ASSOCIATES By: of r A. D. r J)q.oo'?C?- t c? j347S 914 /S t -41