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Home My WebLink About09-4811OufFile No.: 212893 APOTHAK -R & 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. KULWANT SINGH 929 MAPLEWOOD LN ENOLA, PA 17025-2070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. OR-011 Ci v it 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 Our File No.: 212893 APOTHAKP-R & 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. KULWANT SINGH 929 MAPLEWOOD LN ENOLA, PA 17025-2070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0-9- y 9 / / C't v-U 'l?tti•? 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 KULWANT SINGH, an adult individual residing at 929 MAPLEWOOD LN ENOLA, PA 17025-2070. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account #5049948026194128; 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 $1,921.00. 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 $1,921.00 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ? CIATES, P.C. A Law Firm Eng'agedln Debt Collection BY: Dated: 7/15/2009 David Tpothaker, Esquire Our File No.: 212893 f 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 relatiRflo unworn falsification to authorities. David J. )kpothaker, Esquire Attorney for Plaintiff DATE: 7/15/2009 LVNV FUNDING LLC KULWANT SINGH 929 MAPLEWOOD LN ENOLA, PA 17025-2070 STATEMENT OF ACCOUNT Debtor's Name: KULWANT SINGH Account Number: 5049948026194128 Original Creditor: SEARS Balance Due: $1,921.00 Our File No.: 212893 EXHIBIT "A" 0 At .r - cEUt OF TNc PROTHONOTARY 2009 JUL 20 PH 12: 55 CUMBI-:, ,?,,1 ucRoul 7Y PENT ISYN?? !' A. *19-50 PO A`TT1 Cj?-* 14ala1 e aa$r9o Sheriffs Office of Cumberland County R Thomas Kline Sheriff tom, e OFFICE OF THE SHERIFF FILED-4',FF!CE OF THE F RNOTHONOTARY Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor LVNV Funding, LLC vs. Kulwant Singh 2009 JUL 22 PM 2: Z 8 Case Number 2009-4811 SHERIFF'S RETURN OF SERVICE 07/21/2009 05:40 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 21, 2009 at 1740 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kulwant Singh, by making known unto Baljit Kawr, wife of defendant at 929 Maplewood Lane Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 July 22, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF epu eriff fT Our File No.: 212893 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. KULWANT SINGH Defendant Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KULWANT SINGH, in the default of an Answer, in the amount of $1,949.57 computed as follows: Amount claimed in complaint: Less: Amount Paid: Plus: Interest from July 15, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum Attorney fees TOTAL I certify that Defendant, KULWANT SINGH, LN ENOLA, PA 17025-2070. $ 1,949.57 -ess is 929 MAPLEWOOD David J. Apothaker, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4811 $ 1,921.00 ( 0.00) 28.57 0.00 Dated: October 30, 2009 Our File No.: 212893 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. KULWANT SINGH Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4811 Civil Action 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 penalti f 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. pothaker, Esq. Attorney for Plaintiff Dated: October 30, 2009 Our File No.: 212893 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 vs. Plaintiff KULWANT SINGH Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4811 Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. 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 929 MAPLEWOOD LN ENOLA, PA 17025-2070. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defense ?Ajower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in th mi tary. David J. Apoth-Aer, 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. Mpaftwd of Def ftAt _Maupower D to Center Ott-3 0-2009 OT3311 Ngdaty Staens Report Parsttad to @se 5enice'alembe" C`is4 ReWAct v L=r FiVIVN we Begia Dste .kris a Doty States ?ctis c Desty Ead Date Service SI2vGf1 iii L WA"`T Bnstd cn tut rC xm .'s s :;,u h : e hun cd_ iv [1?.fiN d. c; net Pont" arr, fee Xn on imdjcatff ^ the indTE+-Aw status t;pcna saxcUq tut ` xfortsubm data bask; of the Department afl se Manpower Data C'e x, based an rue ' x*cmabtiter you p v%ided, the abo a is the current stag cf e ' _' as tool tare o ttae b, r&mssed Sa%ices (Amy. Alas , %1acirue Corps, As Force, NDAA, Pubes Health, and Coast Crt wd), fq- '!j+ ?"1r." 4haty M. Smn*-Dbma, Director Depashocw Of De t _ *+tuetpaw err Data center 1600 Wj sdm BiY4 Suitt 40D A&gbxt, VA 22209-2593 The W ease, 2+?lattpower Dom (,".ester (D ) is an organitatlon ofte Depxuow cctDcAme dmt maintains the Defense EoroIIurert. and Elplaty Reporting System {DEERS} die which is the official solace of data an dhoWdy for army meat cane and obey efipW systems. The Dorf strongly supports the tmf'amemeA of for See- xt Mcwhers Civil RA Art (50 USC App- §§ 301 et salt, as ameaded) (SCRA) (f iy'tau"as die SoliSers' &nd Sakes' Citif PAdAnt cf 1940). D-NI !C hasissuedbundoeds, Ofdsou9nds of 'uses not pass any iafor'aazan iodinating than the i xhxidud is c twm* an wive d ts' responses, and has experienced a MA emor rata. In the euera the in&idwd tc#crcKcd abm c, dx dry fm* uwasbaer, friend, or rctacsed ivx asserts in My mawer that due indrvirW is on wti=K dsdyr at is athen,nc riaided to the protectiow ofthe CRA, Nvu are strosoy encouraged to obtain firdw verEcaWooftheperxati'istatu;b icl h&apersoals'Saviceviatbe. 1 VRL ti er 4 3rfcsrs ticiml ram s P(„?' i DR } 1f you bamevid"M the person f s cast actirm try and pmt fag to obtainft's a im al sersice velfficatiaa, pururinr prm si,;w of Hre SCRA may be oex+ked agate yon. Sec SQ LW, App. §521(t). IfyyMobtaint itt&xtn: _,+ about the perms (e.g .an SS33, improved accuracy of DOB, a wid& e}, You can sukwA y request again at this NVtb site and h o ti d[ pr side a am certificate fir that This reiqmserefi" active 4* h- inclu&g date the kdvkkW arm ta€t as actisv c €y, fit weer ividiatbe Preceding 367 days. for historical " please caatact the Service SCTtA pointscf-cnttact. More xotna#",ort on "Active lfaW Steraat" Antis c duty std as tepi€ttd in this catificate defined it accordauoe wilts 10 L3 SC § 101(CD(I) fax & period ifn=c than Sts e send da,4' In dw rase of a member oMeNadwal Crumd, iatutdes service under a calf to ages", service mthorized by the Prssidtu su the Secretary of Dekme fvr a p W of nacre than 11) c. v tarps u t ? 2 USC § 34:(f) for purposes cn' respm-Ang to a oak" nncrge ncy dedared by the P4rssideat and supported brFederal fsms A9 cusv Guard Resersm (AGR) >urixers most be assigned against an authatitedstobiRmfion posi tioa in tee mit thty se4rnc•rt. This kddes Navy TARS, Matiuc Carps ARs CCaast Ctuard RPAs. Acme Duty stated also rtppees too &Vwfiormed ` Ser.ice member a0iois ns actK* ditty c ssiamed ai seer ofdre l ,S. Pitt c Fisa fi 5rri i c tr sb a l+ltGt l Clcrmtic a i A sPturic A ' " (NOAA Commissioned Corps) far a period ofmote dim _30 consecutive dags coverage Umier the SCJR.t{ u $#nvrtd er in S: went Cases Cmvsage under the SCRA is broader is some rases and inchides some categories ofpersaw on active duty fix poses a fth e SCRA a? svotdd rear to rtpartcd as ati Aet`rd? D+nY tender tlas rdrt?ratt. '_V m burs orders are amended to extend the period ofacot duty, which wound extend SCRA protec ? Persons as der ng to My on this webike certfitafion %book check to make sere the orders oa wbeh 5CRA protechow art based haw not been amended to road the itt*&e dates, of ur*e, F . som prottctim of ibe $CPA sway extend t* persos who hasv received orders to report for active &st} or to be inducted, but who have not actaatty began action day or actuady reported for indotfta. There Last Date on Active ]Duty entry is isoportaut because a awnber ofprotectioms of SCRA exttud t r. rued tut lass dates ,e duty. T'base xir+ wags rely an this certificate are urged to seek OmMed legal coin to creme that erg rights guaranteed w Service s tamed is SCRA are protected. WARNNG: Tbm cert£rcatc was provided based on a aame and 5SN provided b -y the rszte>;-ster. Pracidmg an err ous Werner Of SS;''•l NMI cause an etroneow cee&ate to be provided. RtgdutIITE2b IN53W X212893 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY LVNV FUNDING LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) KULWANT SINGH ) NO. 09-4811 To: KULWANT SINGH 929 MAPLEWOOD LN ENOLA, PA 17025-2070 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 13, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 COUNTY BAR PAIVID J. APOTHAKER, ESQUIRE AP THAKE& ASSOCIATES, PC A aw Firm Eni g aged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 ??t ?U ? i• ?`1Tf'?? 1, i,_ ? },.. n? i ?, ?' t , _: C?? ?,raB,3b'7 a?'?y !?o-??- ?°'?'°d OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KULWANT SINGH 929 MAPLEWOOD LN ENOLA, PA 17025-2070 LVNV FUNDING LLC Plaintiff vs. KULWANT SINGH Defendant NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4811 Civil Action 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 it/9/o 9