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Home My WebLink About09-4555Our File No.: 201715 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. DANIELLE JONES 936 HUMMEL AVE LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OA - '555 aivil l?;rk 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.: 201715 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. ) DANIELLE JONES ) 936 HUMMEL AVE ) LEMOYNE, PA 17043 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 CA?4' -7'' 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 DANIELLE JONES, an adult individual residing at 936 HUMMEL AVE LEMOYNE, PA 17043. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5424180592954926; and said account was issued to Defendant(s) by CITIBANK., 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 $15,427.63. 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 $15,427.63 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged)in Debt Collection BY: Dated: 7/2/2009 David JJApbthaker, Esquire Our File No.: 201715 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 t9-ynswom falsification to authorities. David J. Ap hh er, Esquire Attorney for Plaintiff DATE: 7/2/2009 LVNV FUNDING, LLC DANIELLE JONES 936 HUMMEL AVE LEMOYNE, PA 17043 STATEMENT OF ACCOUNT Debtor's Name: DANIELLE JONES Account Number: 5424180592954926 Original Creditor: CITIBANK Balance Due: $15,427.63 Our File No.: 201715 EXHIBIT "A" Q t_ r:_ r FILE, T?'r jYA. f,Y 2CC9 J -8 FN (: 36 -*118.50 PD AT H ag??30 ?r T - i'V Sheriffs Office of Cumberland County R Thomas Kline 0 Sheriff Ronny R Anderson C Chief Deputy Jody S Smith Civil Process Sergeant OFFICE -f: T"r s"E.R"F Edward L Schorpp Solicitor LVNV Funding, LLC I Case Number vs. 2009-4555 Danielle Jones SHERIFF'S RETURN OF SERVICE 07/15/2009 01:16 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2009 at 1316 hours, she served a true copy of the within Complaint and Notice, upon the within namec defendant, to wit: Danielle Jones, by making known unto herself personally, defendant at 936 Hummel Avenue Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 July 16, 2009 SO ANSWERS, 10? R THOMAS KLINE, SHERIFF y Sheriff Our File No.: 201715 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING, LLC Plaintiff VS. DANIELLE JONES Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4555 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, DANIELLE JONES, in the default of an Answer, in the amount of $15,540.90 computed as follows: Amount claimed in complaint: $ 15,427.63 Less: Amount Paid: ( 0.00) Plus: Interest from July 2, 2009 to August 28, 2009 at the legal 113.27 interest rate of 6.00% per annum Attorney fees 0.00 TOTAL n $ 15,540.90 I certify that Defendant, DANIELLE JONES,1?t Yown adds is 936 HUMMEL AVE LEMOYNE, PA 17043. David J. Apothaker, Esq. Attorney for Plaintiff Dated: August 28, 2009 •, Our File No.: 201715 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker 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 OF CUMBERLAND COUNTY Plaintiff VS. DANIELLE JONES NO.: 09-4555 Civil Action Defendant CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. A aker, Esq. Attorney for Plaintiff Dated: August 28, 2009 Our File No.: 201715 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker 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 OF CUMBERLAND COUNTY Plaintiff VS. DANIELLE JONES NO.: 09-4555 Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 936 HUMMEL AVE LEMOYNE, PA 17043. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 2220 93, if the Defendant(s) is/are in any branch of the military. oer D ata Center has sent back Mary M. Snavely-Dixon, Director of the efen e jilita our inquiry indicated that the Defendant(s) is/are of in he ry. David J. Apothaker, Esq. Attorney for Plaintiff I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. .4\ + APOTHAKER&AsSOCIATES, P.C. ATTORNEYS AT LAW 1n•,1:?ruv lent _f Defense )+,I<ril -;.?er f iata C. enter ATIVi 2',7: 06 ", )0 Military Status R.epc^It I?F Put suarit ti- the :?ervicctriernbers a ivil Relief Act -4,, Last First,*Afiddle Begin Date :fictive Duty Status Sonice Agency- Name KITES P.kITIELLE Eased on the inf?rmation you have fir7nished, the DMDC does not possess any ;n£otrriation Indicating that the indiwiual is currently on active duty TTp n e<urrhv-q the u,f rrriation data banks Athe Department -,.f Defense Manp,;,wer Data Center, k a6t d -a thF Laf rinnaw n that ,i, tat ?viaed. the aE•ovc is the current states of the individual as to all branches 4the TLSilitary Ak? In t14 _ 4??- Mary M Snavrly I)i , sn, ? ?irectt;r Department ?:fDefense - Manp,>wer Data Ceriter 1F iu "Wilson Blvd- Suite -iW The Defense Manpower Data Center (L)1v DO is an organization of the Department of Defense that maaitams the Defense En::,I-ient and Eligibility F ep-:,rtung System (DEERS) database which is the official source of data on eligibility for trulitari medical care and ether eligibility systerns. The Department of Defense strorjly supports the enforcement of the Servicemembers Civil Relief Act [5u USCS Appx. §§ 501 et segj (SCTI A) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940)_ DI\MChas issued hundreds of thousands of "does not pv:sess any Information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. in the event the undna-iual referenced above, or any family member, friend, or representative asserts in any mariner that the nndiviclual is on active duty, or is :,themse entitled to the protections of the SCRA, you are strongly encouraged t. obtain further ',r(.Ilti?-ati02t vt the per vii:. active duty status by c0iitactuig that per'son's' Military Service via the "defenselrik.trul" TTF-L provided t_., l; vv IY _; c u have e, ideti: e tine person is ;ri active-duty and y'.-u fail t<- obtain this additional lvlilitai,v ervr_ e .."enfication, of the I? . inn tV be uivoked against y? ?u if y _ a obtain tiirther uif.-rrnati; n about kite person i. e g, an SSN, irnpr,ived accuracy of 1fa P. a mi 9dle norm+. :'In subrxut r::r request Igairi at tlir `,J e}: site grid we v;il1 pr Vvle a new certificate. f:tr that query 7lus rest;,nse reflects fluent active duty status orily For historical inf;rmati:.n, please contact the Iv%tat•; :service SCR-A. 1:;oints- f ,,ntar, s ee ht vv.- iP+ welir& a, /hi I-L rt FLT^R.html `,Vi,J1d11Tt3 Tlus r.ertifrcare was pr...vided based on i name and Social Security number (SSIT) pnwided by the requester Pr-- idmg an errcne,?us narne or SSIT will cause an erroneous certificate to be provided. kr ort iL BSf'QOJSFJPHO 520 Fellowship Road C306, Mt. Laurel, NJ 08054 800 672.0215 800 757.4928f 856 780.1000 856 780.1020f 215 634.8920 215 634.8421f Sheriffs Office of Cumberland County R 'I honla; h ling W1, rO Ronny -?' Anderson (iiic?J7i?yx?h[odv S •'111ith n';1 PI ucc?c aw 1=.??tard !. S?h??rhh Vv; i c't ? v.. LVNV Funding. LLC vs. Danielle Jones Case Number 2009-4555 SHERIFF'S RETURN OF SERVICE 07,'15 2009 01 16 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2009 at 1316 hours, she served a true copy of the within Complaint and Notice, upon the within name: defendant, to wit: Danielle Jones, by making known unto herself personally, defendant at 936 Hummel Avi?nue Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to hei personally the said true and correct copy of the same. SHERIFF COST $4240 July 16, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF r y Sheriff 201715 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) DANIELLE JONES ) NO. 09-4555 To: DANIELLE JONES 936 HUMMEL AVE LEMOYNE, PA 17043 NOTICE; RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 10, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 OF THE PROTHONOTARY 2899 SEP -4 PM 2: a 1 C & ??a11ti ,4 r COUNTY l KV App A'tY` p * a3oa.3I V?.? va?? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: DANIELLE JONES 936 HUMMEL AVE LEMOYNE, PA 17043 LVNV FUNDING, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. DANIELLE JONES NO.: 09-4555 Civil Action Defendant NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS _ JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215 9/9/09