HomeMy WebLinkAbout10-2380A
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV Funding LLC AS ASSIGNEE OF
CitiFinancial, Inc.
15 South Main Street
Greenville, SC 29601
Plaintiff
VS.
Bonnie Kimble
111 MAPLE DRIVE
MECHANICSBURG PA 17050
Defendant
CIVIL ACTION
NO: 10 - d380
(1
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NOTICE TO DEFEND
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 to Defend are
served, by entering a written appearance personally or by an 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.
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MIDPENN LEGAL SERVICES
401 EAST LOUTHER STREET
CARLISLE, PA 17013
717-243-9400
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
LVNV Funding LLC AS ASSIGNEE OF
CitiFinancial, Inc. CIVIL ACTION
15 South Main Street
Greenville, SC 29601
Plaintiff
VS.
NO:
Bonnie Kimble
111 MAPLE DRIVE
MECHANICSBURG PA 17050
Defendant
COMPLAINT
Plaintiff, LVNV Funding LLC, by and through its attorneys, Edwin A. Abrahamsen &
Associates, P.C., complains of the Defendant as follows:
1. Plaintiff, LVNV Funding LLC, (hereinafter "Plaintiff") is a Delaware corporation
with a principal place of business located at 15 South Main Street Greenville, SC 29601.
2. The Defendant Bonnie Kimble (hereinafter "Defendant") is an adult individual
residing at 111 MAPLE DRIVE MECHANICSBURG PA 17050.
3. At all relevant. times herein, Plaintiff was engaged in the business of debt pruchase
and collection.
4. Defendant applied for and received a credit card issued by CitiFinancial, Inc. with
the account number 2009080350153.
5. The within account was sold by CitiFinancial, Inc. to LVNV Funding LLC for
valueable consideration and all rights under said accounts were assigned to CitiFinancial, Inc.
6. Use of the CitiFinancial, Inc. credit card was subject to the terms and conditions of
the Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent along to the
Defendant with the credit card. A copy of this document has been requested from CitiFinancial,
Inc., and will be provided upon receipt.
7. Defendant used the CitiFinancial, Inc. credit card with account number,
2009080350153, for purchases, cash advances and/or balance transfers. Use of the card in this
manner constituted acceptance of the terms and conditions and subjects the Defendant to the terms
and conditions contained therein.
8. The Defendant was mailed monthly account statements relative to the Defendant's
use of the subject credit card.
9. The Defendant defaulted under the terms of the Agreement by failing and refusing
to make monthly payments on the account as they became due.
10. The account became delinquent on February 29, 2008.
11. The principal amount was $$10,079.41 at the time of charge-off.
12. Pursuant to the account agreement, any unpaid balance accrues interest at the
contract rate of 6%.
13. The principal amount was $10,079.41 at the time it was received by Plaintiff.
14. The total amount due and owing the Plaintiff including interest, is $11,002.30.
15. Pursuant to the terms of the Agreement, Defendant is liable for Plaintiffs court
costs and reasonable attorney's fees.
WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the
amount of $11,002.30 plus costs of suit and any other relief as the Court deems just and
appropriate.
A. Abrahamsen
. Michael F. Ratchford, squire
Heather K. Woodruf Esquire
Attorney I.D. Nos.: 6285/207805
120 North Keyser ve.
Scranton, PA 185 4
mratchford@e law.com
hwoodruff@eaa-law.com
Phone: 570-558-5510
Fax: 570-558-5511
VERIFICATION
I, Michael F. Ratchford, attorney for Plaintiff,LVNV FUNDING LLC , am fully familiar
with the facts set forth in the within Complaint and am authorized to make this Verification on
behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to
the best of my knowledge, knowing that any false statements are punishable by law pursuant to
18 C.S.A. 4904.
LVNV FUNDING LLC
In the Court of Common Pleas of
Plaintiff CUMBERLAND County,Pennsylvania
Civil Division
VS.
NO: 10-2380
Bonnie Kimble
Praecipe to Withdraw Civil Complaint
Defendant
PRAECIPE TO WITHDRAW
To the Prothonotary of CUMBERLAND County Pennsylvania:
Please enter the above Praecipe to Withdraw the Civil Complaint.
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Thank you, Pri .3
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Michael F. Ratchfor , E quire cr; '°
Edwin A. Abrah en& Associates, P.C. E°3
Lawyer ID# 86 5
120 N. Keyse Avenue
Scranton, PA 18504