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Home My WebLink About09-7618I 1 Our File No.: 217438 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. CHARLES HILL 308 SHERMAN AVE CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: M - rn,I & Civil IerM NOTICF, 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 4 10 Our File No.: 217438 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. CHARLES HILL 308 SHERMAN AVE CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D 9 - -7 G 1,P &';?j I" 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 CHARLES HILL, an adult individual residing at 308 SHERMAN AVE CARLISLE, PA 17013. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #7981924101833119; and said account was issued to Defendant(s) by GE CAPITAL/LOWE'S, 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 $1,549.71. 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 $1,549.71 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for /a' iff A Law Firm Engaged D t Collection BY: David J. Dated: 10/30/2009 Our File No.: 217438 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 under ' understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relatin o unswo falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 10/30/2009 LVNV FUNDING, LLC CHARLES HILL 308 SHERMAN AVE CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 217438 CHARLES HILL 7981924101833119 GE CAPITAL/LOWE'S $1,549.71 EXHIBIT "A" FlE:) ..U ., 2099 HOV -4 hi 2: 53 r vm. so Pb AT7*4 ?t? 1307 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline ~;f ~ ~'-., ,--!-,~- Sheriff I = ' - _"!?Y ,. .. , , Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~~ ~~Si, ~t ~u~ur,,~,r,~~~r wF~ - Z~~~ ~ ~~r r•.. LVNV Funding, LLC vs. Charles Hill Case Number 2009-7618 SHERIFF'S RETURN OF SERVICE 11/06/2009 07:30 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Charles Hill, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Charles Hill. Per current resident of 308 Sherman Avenue Carlisle, PA 17013 the defendant has never lived at this address, his current address is 1423 Bluejay Drive Middleburg, FL. SHERIFF COST: $38.40 November 09, 2009 SO ANSWERS,, < - _, .-, ~-,~" y ~-~.. ,- R THOMAS KLINE, SHERIFF ~~, - ,E