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Home My WebLink About09-2000 Y Our File No.: 198P86 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. KIRK M MCBETH 129 HERON WAY CARLISLE, PA 17013-8747 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. OR - 4000 NOTICE C-y lTtcM 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 A Our File No.: 198986 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. KIRK M MCBETH 129 HERON WAY CARLISLE, PA 17013-8747 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9 oZ Uhl 0 C ?tvM 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 KIRK M MCBETH, an adult individual residing at 129 HERON WAY CARLISLE, PA 17013-8747. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #7981924391827078; and said account was issued to Defendant(s) by LOWE'S, 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 $1,488.96. 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 $1,488.96 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & S CIATES, P.C. Attorney for laintiff A Law Firm End red Debt Collectioi Dated: 3/20/2009 BY: David J. Apothaker, Esquire Our File No.: 198986 VERIFICATION David J. Apothaker 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 belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unworn falsification to David J. App Esquire Attorney for aintiff DATE: 3/20/2009 Current Owner: LVNV Funding LLC Original Creditor: GE Capital) Lowe's Consumer Previous Owner: GE Capital Statement Closing Date: 10/31/2008 12:00:00 AM LVNV Purchase Date: 06/26/2007 Account Origination Date: 07/31/2004 Kirk Mcbeth **"-**-8832 129 HERON WAY CARLISLE, PA 17013 Account number 7981924391827078 Owing Collected Balance Principal $ 1,266.06 $ - $ 1,266.06 Interest $ - $ _ $ _ Atty Fee $ - $ - $ _ Misc Cost $ - $ - $ - New Balance $ 1,266.06 $ - $ 1,266.06 TRANSACTIONS Transaction Date Description Amount This statement is not an original. This statement has been generated on behalf of LVNV Funding LLC, account owner. "W 19. P ? # i D CA - cea "T1 l 1 `17 0 Shetiff s Office of Cumberland County R Thomas Kline ?a?gty of" ?abrrt,y? Sheriff Ronny R Anderson Chief Deputy C> CE OF THE SrERIFF Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant SH 04/06/2009 06:55 PM - Mark Conklin, 2009 at 1955 hours, he se defendant, to wit: Kirk Mcl Carlisle, Cumberland Cou personally the said true ar SHERIFF COST: $32.50 April 06, 2009 2009-2000 LVNV FUNDING L. VS KIRK M. MCBETH FPS RETURN OF SERVICE ;puty Sheriff, who being duly sworn according to law, states that on April 3, ed a true copy of the within Complaint and Notice, upon the within named th, by making known unto himself personally, defendant at 129 Heron Way t, Pennsylvania 17013 its contents and at the same time handing to him correct copy of the same. SO ANSWER .P R THOMAS KLINE, SHERIFF By Deputy Sheriff OF THE RRCTHO MARY 2009 APR - 9 AM 9: 5 # PENN YL"MANIA