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Home My WebLink About09-2042Our File No.: 199158 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 MIDLAND FUNDING LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09-0104a, 0%,t l erwt. STEPHANIE L JONES 22 SPRING ST APT 4 SHIPPENSBURG, PA 17257-1139 Defendant. 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.: 199158 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 MIDLAND FUNDING LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. STEPHANIE L JONES 22 SPRING ST APT 4 SHIPPENSBURG, PA 17257-1139 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9 - ZO y aZ Gant CIVIL ACTION COMPLAINT FIRST COUNT e 1. Plaintiff is MIDLAND FUNDING LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are STEPHANIE L JONES, an adult individual residing at 22 SPRING ST APT 4 SHIPPENSBURG, PA 17257-1139. 3. Plaintiff, MIDLAND FUNDING LLC, is the Assignee and Successor in Interest of Account #6879450129030947; and said account was issued to Defendant(s) by DELL FINANCIAL SERVICES, the Original creditor 4. Defendant received, accepted and used the account to its benefit. S. This account is in default and Defendant(s) has an unpaid balance of $2,394.61. 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 jAS or f Plaintiff and against Defendant(s) for the sum of $2,394.61 and requests this Court award Plaintiff attorney's a costs to the extent permitted by applicable law. APOTHAKER ?CIATES , P.C. A Law Firm Dated: 3/24/2009 BY: David J. Apothaker, Esquire Our File No.: 199158 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 that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn ?d' J. Apothaker, Esquire Attorney for Plaintiff DATE: 3/24/2009 State of Minnesota County of Stearns Midland Funding LLC, Plaintiff -vs- STEPHANIE )ONES Form 400 In Court } ss } Judicial (Circuit/District) Defendant(s) Amy Berscheit, whose business address is 16 McLeland Road, suite 101, saint Cloud, Minnesota, 56303, certifies and says: 1. I am employed by Midland Credit Management, Inc., servicer of this account on behalf of Midland Funding LLC I make the statements herein based upon my personal knowledge. Midland Funding LLC is the current owner of, and/or successor to, the obligation sued upon. 2. That by virtue of such relationship and my employment with Midland Credit Management Inc., I have personal knowledge of all relevant financial information concerning Midland Credit Management Inc.'s account number 8525256715, which includes the following information: that the defendant did fail to make payments on the account and that demand has been made for defendant to make payment of the balance owing on the account described above more than thirty (30) days prior to making this affidavit; that the attorneys representing plaintiff Midland Funding LLC were retained on Midland Funding LLC behalf by me or persons reporting to me for the purpose of collecting the delinquent debt owed on the defendants account number set out above; and that there was due and owing to Midland Funding LLC the sum of $2,010.29. 3. That plaintiffs predecessor in interest soli and assigned all right, title and interest in the defendant's DELL FINANCIAL SERVICES account to the plaintiff. 4. The final statement of account reveals that the defendant owed a balance of $2,010.29 on the following date: 1/16/2006; and that such balance will continue to earn interest at a rate of 6% as annual percentage rate calculated as required by the Federal Truth in Lending Act, until judgment is entered herein, after which interest on the unpaid balance shall accrue as required by law and as set forth within the terms of the judgment. 5. That upon information and belief, based upon business dealings with the defendant (s), the defendant (s), is/are not a minor (s) or mentally incapacitated person (s). I certify under penalty of perjury that the foregoing statements are true and correct. Dated this 10 day of February 2009. Amy Berscheit Affiant's Signature State of Minnesota County of Stearns Subscribed and sworn to (or affirmed) before me on this 10 day of February, 2009 by Amy Berscheit, personally known to me or proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me. Apothaker & Associates, P.C. ` ?/?aDept. 12421 M V M PO Boa 603 Oelo,, PA 19456 ' III??IINI?INIIIIIII¦NI?ININIIIN?IIII?IIII?IIIIN? 06-11-2008 #BWNHLTH 7516.1W 00000 0852 5258 7152# STEPHANIE L JONES 22 SPRING ST APT 4 SHIPPENSBURG, PA 17257.1139 Coelact Information: Tel (800) 939-2353 Hours of Operation: M-Th 6am - 7pm; Fri 6am - 5pm; Sat 6am - 2:30pm PST Current OW1W. Midland Funding LIZ Original CrodAw. DELL FINANCIAL SERVICES Original Account No.: 6879450129030947785 MCM Account No.: 8525256715 Current Balance: $2,298.69 Payment Doe Date: 07-11-2W8 Dear STEPHANIE L JONES, Midland Credit Management, Inc. has made several attempts to contact you regarding the following account Cammt owe : Midland Ftmd*nx LLC p?( Cr+editor : DELL FINANCIAL SERVICES MCM Acao'a Na: 8525256715 Current Balance : $2,298.69 This letter is to' I pon that Midland Credit Maoage?t, Inc. is considering f erwarding this account to an attorney with the i to initiate legal action to sandy the debt Please contact our office immediately at (800) 939-2353 to make arrangements to pay this debt and prevent any legal action on your account. SEE REVERSE SIDE FOR II OMTANT INFORMATION. ?Craft Management, Inc. Please tear offand return lower portion with payment in emlope provided Payment Coupon MCM Account No: 8525256715 Current Balance: 52,298.69 Amount Due: $2,298.69 Mahe Check Payable to: Midland Credit Management, Inc. Payment Doe Date: 07-11-2008 STEPHANIE L JONES 22 SPRING ST APT 4 SIEpPENSBURG, PA 17257-1139 MCM Midland Credit Management, Inc. Department 8870 Los Angeles, CA 90084.8870 12 8525256735 2 0229869 071108 3 INS 3W STATEMENT MCM Account #: 8525256715 Previous Balance: $2,010.29 Original AoooUwt #: 6879450129030947785 Iabeiaot Rate: 6.OOX Statement Date: 06-11-2008 Due Date: 07-11-2008 Accrued Intaaet $288.40 Original Cmditar: DELL FINANCIAL SERVICES New B$ la ce: IJ.C Doe Date Date Received Transactions Amount 07-11-2008 06-11-2008 no above-refareaced account was pumbesed by $2,298.69 Midland Funding U C and is saviood by Midland Condit Management, Inc.{'WQC). The balanoe of $2,298.69 is due now. Please di W all ccnaqwndence to: Midland Credit Manapffait, Inc. Now Balance: $2,298.69 Please underrtand this is a corn smication from a debt collector. This is an attempt to called a debt. Any information obtained will be aced for that parpooe. 0-) OF THE- 209 APR e: 44 4 IS. 50 00 A nY Cwv lalauq Q,T* aa3o'7o Sheriffs Office of Cumberland County R Thomas Kline Edward L Schorpp Sheri " Solicitor Ronny R Anderson Jody S Smith Chief Deputy op, Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/03/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant to wit: Stephanie Jones, 22 Spring Street, Apt. 4, Shippensburg, Cumberland County, Pennsylvania, 17257 but was unable to locate her in his bailiwick he therefore return: the within Complaint as not found as to the defendant, Stephanie Jones. Apartment 4 is vacant and the Post Office advises that the Defendant is Not Known at Address Given. SHERIFF COST: $51.00 April 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Docket No. 2009-2042 Midland Funding LLC v Stephanie Jones Or THE 2909 A FIR -1 Pit-; 3: 50