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Home My WebLink About09-1414a Our File No.: 198357 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road 0300 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associa S, P.C. 520 Fellowship Road C3 6 Mount Laurel, NJ 08054 vs. JENNIFER C FOSTER 212 STATE ST ENOLA, PA 17025-3235 You have been sui take action within twenty ( or by attorney and filing it warned that if you fail to d without further notice for You may lose money or pr YOU SHOULD T OR CANNOT AFFORD ( YOU CAN GET LEGAL I IF YOU CANNO WITH INFORMATION A. A REDUCED FEE OR N( CUMBERLAND COU 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O' - 1414 Civt' LTA NOTICE I in court. If you wish to defend against the claims set forth in the following pages, you must .0) days after this complaint and notice are served, by entering a written appearance personally writing with the court your defenses or objections to the claims set forth against you. You are so the case may proceed without you and a judgment may be entered against you by the court ny money claimed in the complaint or for any other claim or relief requested by the plaintiff. perty or other rights important to you. LKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER NE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU 3OUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT FEE. BAR ASSOCIATION Y Our File No.: 198357 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 LVNV FUNDING LLC c/o Apothaker & Associa 520 Fellowship Road C31 Mount Laurel, NJ 08054 vs. JENNIFER C FOSTER 212 STATE ST ENOLA, PA 17025-3235 COURT OF COMMON PLEAS es, P.C. ) CUMBERLAND COUNTY 6 _ NO.: 01- /y!I intiff, ) ndant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff i LVNV FUNDING LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant s) is/are JENNIFER C FOSTER, an adult individual residing at 212 STATE ST ENOLA, PA 17025-3235. 3. Plaintiff, VNV FUNDING LLC, is the Assignee and Successor in Interest of Account #8060500375296; and said account was issu to Defendant(s) by SEARS, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This accou t is in default and Defendant(s) has an unpaid balance of $1,462.84. A true and correct copy of the total due and owing is a ched 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 d WHEREFORE, PI $1,462.84 and requests this ( d has been made, Defendant(s) has failed to make payment of the amount due as above. f demands judgment in favor of Plaintiff and against Defendant(s) for the sum of award Plaintiff attorney's fees osts to the extent permitted by applicable law. APOTHAKER & SS IATES, P.C. A Law Firm Dated: 3/2/2009 BY: David J. Apotl>r, Esquire Our File No.: 198357 4 t VERIFICATION Verification, and that the knowledge, information, of 18 Pa.C.S.A. 4904 hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this tements made in the foregoing Civil Action Complaint are true and correct to the best of my belief. The undersigned underLr, ements therein are made subject to the penalties to unworn falsification to au David J. ApAttorney for Plaintiff DATE: 3/2/2009 Current Owner: LVNV F Original Creditor: Sears Previous Owner: Sears Statement Closing Date: LVNV Purchase Date: of Account Origination Date LLC 0/31/2008 12:00:00 AM ?3/2003 05/01/1998 Account number 8060500375296 JENNIFER FOSTER **"-**-1411 212 STATE ST ENOLA, PA 17025 TRANSACTIONS Transaction Date 03/21/2005 02/21/2005 Owing Collected Balance Principal $ 1,087.45 $ - $ 1,087.45 Interest $ 30.00 $ 30.00 $ - Atty Fee $ - $ - $ _ Misc Cost $ - $ _ $ _ New Balance $ 1,117.45 $ 30.00 $ 1,087.45 Interest Interest Amount 15 This statement is not an original statement has been generated on behalf of LVNV Funding LLC, account owner. s ? CT qu? Zn Sheriffs Office of Cumberland County R Thomas Kline ?a ,tr of cumber ?d Edward L Schorpp Sheri Solicitor Ronny R Anderson f Jody S Smith Chief Deputy orrCE OF r14E SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/11/2009 11:13 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on March 11, 2009 at 1113 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer C. Foster, by making known unto Scott Foster, husband of Defendant, at 25 W. Locust Street, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.92 (PAID) March 13, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Dep y She ri Docket No. 2009-1414 LVNV Funding LLC v Jennifer C Foster C"J i`r?j:?7 mac. "b r`.a