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Home My WebLink About09-6627Our File No.: 213473 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. HOLLY BRULIA 14 ALTOONA AVE ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (A - (.Q10o11I Owit I?t'iM NOTTCF, 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.: 213473 APQTHAKER & 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. HOLLY BRULIA 14 ALTOONA AVE ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: U 9- 4 4 x 7 (v;2? -rr-,? 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 HOLLY BRULIA, an adult individual residing at 14 ALTOONA AVE ENOLA, PA 17025. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #6011310000502143; and said account was issued to Defendant(s) by GE CAPITAL, 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 $6,712.61. 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 favor of Plaintiff and against Defendant(s) for the sum of • $6,712.61 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Pl ' i A Law Firm Engaged in eb Collection BY: Dated: 9/28/2009 David J. Apoth*k&, Esq Our File No.: 213473 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 relating to,64s orn falsification to authorities. David J for DATE: 9/28/2009 LVNV FUNDING, LLC HOLLY BRULIA 14 ALTOONA AVE ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: HOLLY BRULIA Account Number: 6011310000502143 Original Creditor: GE CAPITAL Balance Due: $6,712.61 Our File No.: 213473 EXHIBIT "A" 0 fil M-J;-FICE OF THE PRAT! 7-,N. r 'ARY 1009 OCT -S PM 3: 15 CUty? ;NITY CIG? rya-90? Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant FILED-0It FIICE OF THE (??"??^ TARY 2009 OCT -7 Phi 3: 22 Edward L Schorpp Solicitor LVNV Funding, LLC I Case Number vs. 2009-6627 Holly Brulia SHERIFF'S RETURN OF SERVICE 10/06/2009 05:12 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 6? 2009, at 1710 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Holly Brulia, by making known unto Holly Burlia, personally, at 14 Altoona Avenue, 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 October 07, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF De ;u't'y Sheriff -;;; LVNV FUNDING,LLC c/o Apothaker & Ass., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6627 Civil Civil Action e n an Ass ? AND NOW, comes the Defendant, Holly Brulia, by and through her attorney, Gary L. HOLLY BRULIA, D r- d t Kelley, and files this Answer to Plaintiffs Complaint and, in support thereof, respectfully responds as follows: 1. Admitted. 2. Admitted. 3. Defendant is without sufficient knowledge to ascertain the truth or falsity of this averment. Hence, it is denied. 4. Denied as stated. 5. Denied and strict proof thereof is demanded at trial.. 6. Denied and strict proof thereof is demanded at trial.. 7. Denied and strict proof thereof is demanded at trial.. WHEREFORE, based upon all of the foregoing, Defendant respectfully requests that this Honorable Court find in Defendant's favor. Respectfully submitted, 0? - 41 G ry L Kelley ID No. 46801 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant LVNV FUNDING,LLC c/o Apothaker & Ass., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054, Plaintiff V. HOLLY BRULIA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6627 Civil Civil Action CERTIFICATE OF SERVICE I, GARY L. KELLEY, Esquire, attorney for DEFENDANT in the above-captioned matter, do hereby certify that I served a true and correct copy of DEFENDANT'S ANSWER on counsel for PLAINTIFF by depositing same in the U.S. Mail, first class, postage prepaid, on the 6TH day of November, 2009, addressed as follows: David J. Apothaker, Esq. 520 Fellowship Road C306 Mount Laurel, NJ 08054 LAW OFFICES OF GARY L. KELLEY GAR L. KELLEY, squ e I.D. O l 3117 Chestnut Street Camp Hill, PA 17011 (717) 612-1484 Attorney for Defendant FILED-v OFTHLPMJ'} TAR 2099 NOV -6 PH 12: 00 GUS r? : .? Y Our File No.: 213473 LVNV FUNDING, LLC Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-6627 HOLLY BRULIA ) Civil Action c o - Defendant ) m rn _ ° xm - a M- r ?' _ rn ° PRAECIPE FOR APPOINTMENT OF ARBITRATORS C, - ro TO THE HONORABLE THE nc") ? _x o- n , JUDGES OF SAID COURT: n ro m " C.n b Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully repr-&ents- th aT- 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $6712.61. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff HOLLY BRULIA Benjamin J. Cavallaro, Esquire 2806 SUNSET COURT 520 Fellowship Road C306 GRANTHAM, PA 17027 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respe November 22, 2010 AND NOW, and as prayed for. ORDER OF COURT Esquire tD?b as;?ss 20, in consideration of the foregoing petition, Esq., and Esq., Esq., are appointed arbitrators in the above captioned action By the Court, Our File No.: 213473 LVNV FUNDING, LLC Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 09-6627 HOLLY BRULIA ) Civil Action c o --n Defendant ) qm _ PRAECIPE FOR APPOINTMENT OF ARBITRATORS r'' oc? ? o-n n TO THE HONORABLE, THE JUDGES OF SAID COURT: c r\,) z; C,?-i Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfull y reprd'senfs' th aT- 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $6712.61. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff HOLLY BRULIA Benjamin J. Cavallaro, Esquire 2806 SUNSET COURT 520 Fellowship Road C306 GRANTHAM, PA 17027 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respe November 22, 2010 ORDER OF COURT Esquire as??SS - AND NOW, e , 20 /d, in consideration of the foregoing petition, 4 Esq., and Esq. _ , and Esq., are appointed arbitrators in the above captioned action 0 as pray f ago C.-) oP Q, =)-. o< (26?t'es em'at'? z U- C:) o M ? Q. Z: ? By the Co ? , -j?- :y= CM C= MW a_ 44 A C) ? N L? v? V ??ti?r rl?(r L- L C Plaintiff u L-i A- Defendant In The Court of Common Pleas of Cumberland County, Pennsylvania No. 09 - w (0 Z 1 Civil Action - Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United with fideY Signat Sig ture pAr\lk O l11 gztkcaz- Name (Chairman) V-aA?--t_ i Law Firm 2351 rVysi f '-l Address Namv a Law irm -?9/ A/ ? 114j:-T- Address C?? & 8 ? .2 0// Cori, ot I --?v 3 City, Zip City, Zip City, Zip Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) 6AAtAQ1 Tb ALAI N I IF-1ri4g2s-ou Date of Hearing: A?.r444 tVZol Date of Award:_ l\Mko (Chairman) Notice of Entrk/of Award Now, the 1-2 day of I' are A , 20 // , at 3.'Y3 , P M., the above award was entered upon the docket and notice thereof given by mail to the parties or their attorneys. Arbitrators' compensation t be paid upon appeal: $ f Prothonotary ion Name SG,d?i SG????vcn :Snfj Law Firm ZG Wiyj 9'S 4 S-?rtl Address , dissents. 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