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Home My WebLink About09-0202.. Ow File No.: 185740 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. DAVID J MOORE 244 MEALS DR CARLISLE, PA 17015-3183 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.: 185740 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. ) DAVID J MOORS ) 244 MEALS DR ) CARLISLE, PA 17015-3183 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1 • Plaintiff is LVNV FUNDING, LLC c% Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2• Defendant(s) is/are DAVID J MOORS, an adult individual residing at 244 MEALS DR CARLISLE, PA 17015-3183. 3 • Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #6035320052766191; and said account was issued to Defendant(s) by HOME DEPOT, 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 $6,740.95. 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 $6,740.95 and requests this Court award plaintiff attorney's fees and costs to the extent permitted by applicable law. Al'OTHAKER & OCIATES, P.C. Attorn fo Plaintiff_/ A Law Firm E age in Debt ~'ollect;nr BY: David J. baker, Esquire Dated: 12/31/2008 Our File No.: 185740 VERIFICATION David J. Anothaker Esquire hereby states that I am counsel for plaintiff in this action, and that I am autho razed to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and co rrect to the best of my knowledge, information, and belief. made subject to the penalties of 18 Pa.C.S.A. 4904 David undersigned understands that the statements therein are to unsworn falsification to authorities. ker, Esquire Plaintiff DATE: 12/31 /2008 Current Owner: LVNV Funding LLC Original Creditor: Home Depot Previous Owner: Citibank Statement Closing Date: 9/12/2008 12:00:00 AM LVNV Purchase Date: 04/29/2008 Account Origination Date: 04/02/1997 David Moore "`"-""-7240 244 MEALS DR CARLISLE, PA 17015 TD A 61e w nr..v... Account number ~In9 Collected 6035320052766191 Balance Principal Interest $ 5,956.63 $ $ _ $ 5,956.63 Atty Fee _ _ $ $ $ $ Misc Cost $ _ $ _ $ - $ - New Balance $ 5,956.63 $ - $ 5,956.63 - - - -- . _. ~.... v..v Transaction Date Amount This statement is not an on incl. This statement has been generated on behalf of LVNV Funding LLC, account owner. ~ ~ N ~ " oo ~~ ~ i ~ ~ ~ ~ ~ ~ ~ cn N ~ d ~a'- -~ ~rC? ~ W ~ CT "< ~~„