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Home My WebLink About09-0203'Our File No.: 185500 1~POTHAKER & 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. FAHD A MALIK 820 PENNSYLVANIA AVE LEMOYNE, PA 17043-1530 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Qf; - Oc1.d 3 ...~. iV i l lc~ hM 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.: 185500 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney LD.#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. COURT OF COMMON PLEAS CUMBERLAND COUNTY FAHD A MALIK 820 PENNSYLVANIA AVE LEMOYNE, PA 17043-1530 Defendant. 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 FAHD A MALIK, an adult individual residing at 820 PENNSYLVANIA AVE LEMOYNE, PA 17043-1530. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5121079716257453; and said account was issued to Defendant(s) by SEARS, 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 $11,663.61. 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 $11,663.61 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER AS CIATES Atto y for laintiff A Law Firm E aged De Coll BY: David J. Apothaker, Esquire Dated: 12/31 /2008 Our File No.: 185500 VERIFICATION David J. Anothaker 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 belie% j~ undersigned understands that the statements therein aze made subject to the penalties of 18 Pa.C.S.A. 49 4 rela ng to orn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 12/31/2008 ~, Current Owner: LVNV Funding LLC Original Creditor: Sears Previous Owner: Citibank Statement Closing Date: 9/12/2008 12:00:00 AM LVNV Purchase Date: 09/20/2006 Account Origination Date: 08/14/2002 Fahd Malik ""'-"-7914 820 PENNSYLVANIA AVE LEMOYNE, PA 17043 Account number 5121079716257453 Owing Collected Balance Principal $ 10,473.89 $ - $ 10,473.89 Interest $ 50.00 $ 50.00 $ Atty Fee $ _ $ _ $ Misc Cost $ _ $ _ $ _ New Balance S 10,523.89 $ 50.00 ; 10,473.89 TRANSACTIONS Transaction Date no~,.~~.,+,,,., ~..., ... - -- --- ra ment $ 50.00 This statement is not an original This statement has been generated on behalf of LVNV Funding LLC, account owner. ~ ~ ~ ~~ _~ ~ r N O K ~.: v ~` ( '3 .+'' .~~ n.~ a ~ ~~ t~; ~ Z~ Z 7 ~ t~`,' ; ~~ 1-^~ `~