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Home My WebLink About09-19134- ? Our File Not. 198834 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. ALEXANDER OPILO 715 SHERWOOD DR CARLISLE, PA 17013-3535 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Oq - 1q15 NOTICE Liv; ( T?e.,-?, 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 Pile No.? 198834 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 Attome s for Plaintiff LVNV FUNDING LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. ALEXANDER OPILO 715 SHERWOOD DR CARLISLE, PA 17013-3535 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0,?. 19 13 ew iv( 7A-Z, 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 ALEXANDER OPILO, an adult individual residing at 715 SHERWOOD DR CARLISLE, PA 17013-3535. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #6011314001006955; and said account was issued to Defendant(s) by WAL-MART, 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 $1,981.54. 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 $1,981.54 and requests this Court award Plaintiff attorney's fees costs to the extent permitted by applicable law. APOTHAKER ASS IATES, P.C. Attorne for aintiff A Law Firm Eng ged . Debt Collectinn BY: Dated: 3/18/2009 David J. Apo) r, Esquire Our File No.: 198834 VERIFICATION David J. Apoth aker S wire hereby states that I am counsel for plaintiff in this action, and th at 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 undersigned understands of 18 Pa.C.S.A. 4904 relating to unworn falsification to David J. API( Attorney the statements therein are made subject to the penalties ker, Esquire Plaintiff DATE: 3/18/2009 Current Owner: LVNV Funding LLC Original Creditor. GE Capital) Wal-Mart Previous Owner: GE Capital Statement Closing Date: 10/31/2008 12:00:00 AM LVNV Purchase Date: 05/03/2007 Account Origination Date: 09/11/2005 Alexander Opilo ***-**-2484 715 SHERWOOD DR CARLISLE, PA 17013 TRAUQA/-T?nuc. Account number Owing Collected 6011314001006955 Principal $ 1,687.03 $ Balance _ $ 1 Interest $ _ ,687.03 Atty Fee $ $ $ Misc Cost $ - New Balance 1,687.03 $ - $ 1,687.03 Transaction Date This statement is not an on incl. This statement has been generated on behalf of LVNV Funding LLC, account owner. runvuni t'?n* 400' cn I tn rIO Sheriffs Office of Cumberland County R Thomas Kline Sheriff ?at??ttr °i `°'ribrrr?i?0 Edward L Schorpp _ Solicitor Ronny R Anderson Jody S Smith Chief Deputy Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/30/2009 05:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 30, 2009 at 1730 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Alexander Opilo, by making known unto himself personally, defendant at 715 Sherwood Drive Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $3:.50 March 31, 2009 2009-1913 LVNV FUNDING LLC VS ALEXANDER OPILO SO ANSWERS, R THOMAS KLINE, HERIFF By zz? 4 Depu Sheriff Fil.Ep4)FFM OF THE PR(} i F?ONOTARY 2009 APR -2 PM 3= 30 cUt 6L:1-L-A t .:: OUNTY PENNSYLVAMA ,06 Our File No.: 198834 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. ALEXANDER OPILO NO. 09-1913 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Eng in Debt Collection By: David J. Apothaker, Esquire Dated: June 8, 2009 OF 11-41E P ' -J, rARY 2909 JUN 15 P i 3: ? 6