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Home My WebLink About08-5406 Our File No.: 173 846 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. MICHELE E JOHN 1 CHESTER RD APT 2 ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: og - &fo(p ?- I Terri 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.: 173846 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. MICHELE E JOHN 1 CHESTER RD APT 2 ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 N- -7404 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 MICHELE E JOHN, an adult individual residing at 1 CHESTER RD APT 2 ENOLA, PA 17025. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5491130092130376; and said account was issued to Defendant(s) by CITIBANK, 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 $31,170.19. 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 W WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of '$31,170.19 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law APOTHAKER & AS IATES, P.C. Attorney Vd Pl tiff A Law Firm Enaag in ebt Collection BY: Dated: 9/5/2008 David J. Apd(Wr, Esquire Our File No.: 173846 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 relao unsworn falsification to authorities. David J. pothaker, Esquire Attome r Plaintiff DATE: 9/5/2008 w MICHELE E JOHN 1 CHESTER RD APT 2 ENOLA, PA 17025 STATEMENT OF ACCOUNT LVNV FUNDING, LLC Debtor's Name: MICHELE E JOHN Account Number: 5491130092130376 Original Creditor: CITIBANK Balance Due: $31,170.19 Our File No.: 173846 EXHIBIT "A" 1 Q '?: A r? ?i W V IX? 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05406 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS JOHN MICHELE E STEVE BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE JOHN MICHELE E the was served upon DEFENDANT , at 1310:00 HOURS, on the 15th day of September, 2008 at 1 CHESTER RD APT 2 ENOLA, PA 17025 by handing to MIKE POSTERARO SR, BOYFRIEND, ADULT IN CHARGE 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 15.00 Affidavit .00 Surcharge 10.00 n .00 lUla???? 7'' 43.00 Sworn and Subscibed to before me this day So Answers: y? ss? R. Thomas Kline 09/15/2008 APOTHAKER & ASSOCIATES By:? Deputy Sheriff of A. D. Our File No.: 173846 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. MICHELE E JOHN Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-5406 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged Debt Collection By: David J. Dated: December 8, 2008 y?+J C= Lw„ ? •a r ? Iet t,3 ? ?F ?? 4y . s" ?o ?? i7i