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Home My WebLink About08-7383w 14. Out File No.: 175204 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. RANGIN MOHAMMADI 1 GRAYSTONE MANOR DRIVE CAMP HILL, PA 17011-1500 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 03 - 7383 NOTICE eivi l - eryk 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 Ou File No.: 175204 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. RANGIN MOHAMMADI 1 GRAYSTONE MANOR DRIVE CAMP HILL, PA 17011-1500 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o Q- 7313 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 RANGIN MOHAMMADI, an adult individual residing at 1 GRAYSTONE MANOR DRIVE CAMP HILL, PA 17011-1500. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5424181039771360; 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 $5,126.06. 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. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,126.06 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & i'Debt CIATES, P.C. Attorney or intiff A Law Firm Ena Zed Coilectioi BY: Dated: 12/11/2008 David J. ApbAli(ker, Esquire Our File No.: 175204 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 unArsigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat to worn falsification to authorities. David J. Ap< Attorney ker, Esquire Plaintiff DATE: 12/11/2008 Current Owner: LVNV Funding LLC Original Creditor: Citibank Previous Owner: Citibank Statement Closing Date: 6/27/2008 12:00:00 AM LVNV Purchase Date: 01/22/2008 Account Origination Date: 01/19/2005 Rangin Mohammadi ***-**-9974 1 GRAYSTONE MANOR DRIVE CAMP HILL, PA 17011 Account number 5424181039771360 Owing Collected Balance Principal $ 3,815.12 $ - $ 3,815.12 Interest $ - $ - $ - Atty Fee $ - $ - $ - Misc Cost $ - $ - $ - New Balance $ 3,815.12 $ - $ 3,815.12 TRANSACTIONS Transaction Date Description Amount This statement is not an original. This statement has been generated on behalf of LVNV Funding LLC, account owner. od -? O oo v 4 a n ? rri c a. T SHERIFF'S RETURN - REGULAR CASE NO: 2008-07383 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LVNV FUNDING LLC VS MOHAMMADI RANGIN DENNIS FRY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE MOHAMMADI RANGIN DEFENDANT was served upon the at 1113:00 HOURS, on the 29th day of December-, 2008 at 1 GRAYSTONE MANOR DRIVE CAMP HILL, PA 17011-1500 by handing to AHMAD SHARIFI, BROTHER, 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 11.70 .00 10.00 R. Thomas Kline .00 39.70 12/30/2008 APOTHAKER & ASSOCIATES 4 By: day De uty Sheriff; ,, A.D. ._ T?, ti ;,' 4::: ? = i t„_ ? :.?:. t ?? ' C`.? F ...?'?. '... N. ? #.. "tl .. ry - a ,:.... y ? Our File No.: 175204 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. RANGIN MOHAMMADI Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-7383 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys r laintiff A Law Firm End e m Debt Collection By: David J. Apothaker, Esquire Dated: April 16, 2009 FILE 0, E- OF THE Pr,' 2009 APR 27 Pi'`i U: 09