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HomeMy WebLinkAbout09-0171r Our File No.: 189843 APO'THAKER & 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. CARLA J BRADLEY 1036 W FOXCROFT DR CAMP HILL, PA 17011-1235 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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.: 189843 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. CARLA J BRADLEY 1036 W FOXCROFT DR CAMP HILL, PA 17011-123 5 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 CARLA J BRADLEY, an adult individual residing at 1036 W FOXCROFT DR CAMP HILL, PA 17011-1235. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #6008890882582000; 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 $2,358.65. 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 $2,358.65 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. ApOTHAKER & S OCIATES, P Attorne fo Plaintiff A Law Firm Eng a in Debt lec BY: Dated: 12/26/2008 David J. Apl(fhaker, Esquire Our File No.: 189843 i ' VERIFICATION David J. A thaker Es uire 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 belie made subject to the penalties of 18 Pa.C.S.A. 4904 David J. Apothaker, Esquire Attorney for Plaintiff ' ;that the statements therein are to authorities. DATE: 12/26/2008 LVNV FUNDING LLC CARLA J BRADLEY 1036 W FOXCROFT DR CAMP HILL, PA 17011-123 5 STATEMENT OF ACCOUNT Debtor's Name: CARLA J BRADLEY Account Number: 6008890882582000 Original Creditor: JC PENNEY Balance Due: $2,358.65 Our File No.: 189843 EXHIBIT "A" ~, ~ o`o ~ ~ 'D .=t, b ~' -C r "~ ,~ -~. ~" ~© - _ ~! ~ ~ _ :~' t ~ 2~, ~ C~j r~ ~ y ~ i J n'i ' i ""['