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Home My WebLink About09-2626J Our File No.: 203 812 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. LINDA L MILLER 1153 PHEASANT DR N CARLISLE, PA 17013-1252 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. OQ - pZ,(o g(v eivii Tern, 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 C Our File No.: 203812 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. LINDA L MILLER 1153 PHEASANT DR N CARLISLE, PA 17013-1252 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 0 q- 21- '2'- 0ia 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 LINDA L MILLER, an adult individual residing at 1153 PHEASANT DR N CARLISLE, PA 17013-1252. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #5484079978079; 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 $2,718.99. 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 $2,718.99 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS TES, P.C. Attorney f Pr tiff A Law Firm Ena. d ' ebt ColleeetioI BY: David J. Apothaker, Esquire Dated: 4/10/2009 Our File No.: 203812 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 belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating,Cb'?sworn falsification to authorities. David J. Aoothaker, Esquire Attorney for Plaintiff DATE: 4/10/2009 LINDA L MILLER 1153 PHEASANT DR N CARLISLE, PA 17013-1252 Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 203812 LVNV FUNDING LLC STATEMENT OF ACCOUNT LINDA L MILLER r 5484079978079 SEARS $2,718.99 EXHIBIT "A" APi Y 27 Pit ''• C Ci ! {l „ y $078.So PO ATr--/ W 13oa39 U* 2&4 a9 7 Sheriffs Office of Cumberland County R Thomas Kline ?,tr of Climb rrf Edward L Schorpp Sheriff w? Solicitor 3 ? rlyt • i-°; Ronny R Anderson Jody S Smith Chief Deputy OFFICE . ` -E ?ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/01/2009 10:10 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2009 at 1010 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Linda L. Miller by making known unto Linda L. Miller personally, at 1153 Pheasant Drive North, Carlisle, Cumberland County, Pennsylvania, 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $32.50 May 05, 2009 Docket No. 2009-2626 LVNV Funding v Linda Miller SO ANSWERS, R THOMAS KLINE, SHERIFF J? De t Sheriff Q FT r r ?. co t_ _1 i I ?? CD ?? Our file No.: 203812 APOTHAKER & ASSOC TES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 LVNV FUNDING LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. LINDA L MILLER Defendant. DOCKET NO.: 09-2626 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on June 11, 2009, STIPULATED by and between Plaintiff, LVNV FUNDING LLC, and Defendant, LINDA L MILLER parties as follows: 1. Defendant agrees to pay the sum of $2,851.24, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $2,851.24 shall be paid by the by Defendant, LINDA L MILLER, to the attorneys for Plaintiff in the following manner: a. $90.00 to be paid on or before the 19`h day of each month, beginning June 19, 2009 until paid in full. All checks are to made payable to LVNV FUNDING LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 203812 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $2,851.24, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to LINDA L MILLER by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys fo Pl A Law Firm Engap?d Debt Collection F. Scian, Esquire La& v LINDA L MILLE F1 L 2009 JUii 241 Our File No.: 203812 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 Plaintiff, vs. LINDA L MILLER Defendant. ME FRAONOTARY 2?J 12 JAN 25 PM 1:27 CJ' MBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2626 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. AP A Law Firm By: David J. Dated: 1/18/2012 II?IIIN?I??Inlnl?ll?l??l?l ASSOCIATES, P.C. for Plaintiff d in Debt Collection , Esquire