HomeMy WebLinkAbout09-8447Our File No.: 223438
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.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. 09 - 8441 l?ivi t r
SUSAN GELNETT
120 VALLEY ST
SUMMERDALE, PA 17093
Defendant.
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.: 223438
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.
SUSAN GELNETT
120 VALLEY ST
SUMMERDALE, PA 17093
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO..
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 SUSAN GELNETT, an adult individual residing at 120 VALLEY ST
SUMMERDALE, PA 17093.
3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account
#2009080152111; and said account was issued to Defendant(s) by CITIFINANCIAL, INC, 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 $8,979.25. 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
$8,979.25 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & ASSOCIATES, P.C.
Attorney Plaintiff
A Law Firm En g in Debt Collection
BY:
David J. Mothaker, Esquire
Dated: 11/30/2009
Our File No.: 223438
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 relatinjyf' nsworn falsification to authorities.
David J
for Plaintiff
DATE: 11/30/2009
LVNV FUNDING, LLC
SUSAN GELNETT
120 VALLEY ST
SUMMERDALE, PA 17093
STATEMENT OF ACCOUNT
Debtor's Name: SUSAN GELNETT
Account Number: 2009080152111
Original Creditor: CITIFINANCIAL, INC
Balance Due: $8,979.25
Our File No.: 223438
EXHIBIT "A"
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Our File No.: 223438
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.
SUSAN GELNETT
2 2
NtjS Y L VA N1A
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 09-8447
Defendant.
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER &
A Law Firm
By:
David J
iOCIATES, P.C.
Plaintiff
n Debt Collection
, Esquire
Dated: 5/24/2012
?iN