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Home My WebLink About09-4474Our File No.: 195705 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. MARK A COY 501 BRENTON ST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: pq - g4g4 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.: 195705 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. MARK A COY 501 BRENTON ST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.- 1 VY y 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 MARK A COY, an adult individual residing at 501 BRENTON ST SHIPPENSBURG, PA 17257. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5049948044841718; 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 $4,648.22. 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 $4,648.22 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for tiff A Law Firm Engage in ebt Collection BY: Dated: 6/30/2009 David J. Apoter, Esquire Our File No.: 195705 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 rel ng t unworn falsification to authorities. -i J'Apothaker, Esquire Attorney for Plaintiff DATE: 6/30/2009 LVNV FUNDING, LLC MARK A COY 501 BRENTON ST SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: MARK A COY Account Number: 5049948044841718 Original Creditor: SEARS Balance Due: $4,648.22 Our File No.: 195705 EXHIBIT "A" 0 RLFD- ;-'- 01-' OF THE 2009 JUL -3 fi i 12: IS 3 GUir+?' JJINT)f $?8. --)o po ATIY P...T# aa??ot Sheriff s Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant CE C` '-'?ERWF Edward L Schorpp Solicitor FF[ r , CF TL tt "' .JU 1,3 o- ti ? ? ? r??17`7r L i }r, LVNV Funding, LLC vs. Mark A Coy SHERIFF'S RETURN OF SERVICE Case Number 2009-4474 07/0812009 08:39 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2009 at 2039 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark A. Coy, by making known unto himself personally, defendant at 501 Brenton Street Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to hirr personally the said true and correct copy of the same. SHERIFF COST: $46.00 July 09, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Dep y Sher' f t • r r Our file No.: 195705 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 38423 LVNV FUNDING, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. MARK A COY Defendant. DOCKET NO.: 09-4474 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 July 17, 2009, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, MARK A COY parties as follows: 1. Defendant agrees to pay the sum of $5,285.53, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $750.00 have been applied to the amount of $5,285.53, and the amount due and owing as of July 17, 2009 is $4,535.54. 3. The sum aforesaid of $4,535.54 shall be paid by the by Defendant, MARK A COY, to the attorneys for Plaintiff in the following manner: a. $250.00 to be paid on or before the 15'' day of each month, beginning August 15, 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.: 195705 4. 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 $5,285.53, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. 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 MARK A COY by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged' De ollection By: im erl F. Scian, Esquire MXAk A COY C kt L A)1 t-? l r, I 1?n CIA 7j.. 1`4Y 2009 AUG -5 F !1 11 12: 0 I Cl Our file No.: 195705 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 38423 LVNV FUNDING, LLC Plaintiff, VS. MARK A COY Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-4474 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 July 17, 2009, STIPULATED by and between Plaintiff, LVNV FUNDING, LLC, and Defendant, MARK A COY parties as follows: 1. Defendant agrees to pay the sum of $5,285.53, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $750.00 have been applied to the amount of $5,285.53, and the amount due and owing as of July 17, 2009 is $4,535.54. 3. The sum aforesaid of $4,535.54 shall be paid by the by Defendant, MARK A COY, to the attorneys for Plaintiff in the following manner: a. $250.00 to be paid on or before the 15th day of each month, beginning August 15, 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 r . Ilk i ' ' Our file No.: 195705 4. 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 $5,285.53, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. 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 MARK A COY by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm EBy: Esquire d CD 1/0 310 .4 MARK A COY C kLto x,11 Gp- 4? 1Q ["tik /? V C4 u? 1 6 3? , FILE"'. L??U9 i:Jt7 1 2 I l1 12: L Our File No.: 195705 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. MARK A COY OF THFEILEO-OFFICE PROTHONOTAR% 2010 DEC 17 PM 1.3 3 CUMBERLAND COUNN y PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-4474 CIVIL TERM Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOC TES, P.C. Attorneys for nDt ff A Law Firm Engaged Collection By: David J. Apoth r, Esquire Dated: 12/8/2010 IIIIIIIIIIIIIIII