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HomeMy WebLinkAbout10-3526Our File No.: 243976 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Frsquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 Plaintiff, VS. JANICE L SPAHR 33 W LOCUST ST MECHANICSBURG, PA 17055 Defendant. Fier . Y 2CiM0 2.6 AID(I- 50 CU1Y Y S A '1! COURT OF COMMON PLEAS r' LV t CUMBERLAND COUNTY NO.: 10 - 35a.(v 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 O -*qa• oo Pis ATt-l CV1# 18 883 o? 49 W Our File No.: 243976 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LVNV FUNDING, LLC 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Plaintiff, VS. JANICE L SPAHR 33 W LOCUST ST MECHANICSBURG, PA 17055 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING, LLC, 15 SOUTH MAIN STREET STE 500, GREENVILLE, SC 29601 2. Defendant(s) is/are JANICE L SPAHR, an adult individual residing at 33 W LOCUST ST MECHANICSBURG, PA 17055. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #5121079717195280; and said account was issued to Defendant(s) by CITIBANK/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 $14,140.06. 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 $14,140.06 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A OCIATES, P.C. Attorney or laintiff A Law Firm Ens ed ' Debt Colleetioi Dated: 5/19/2010 BY: David J. A?UKaker, Esquire Our File No.: 243976 VERIFICATION David J. Apothaker Esquire hereby states that I am counsel for plaintiff in this action, and that I am authori zed 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. undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 to unworn falsification to authorities. David J. Akthaker, Esquire Attorney or Plaintiff DATE: 5/19/2010 LVNV FUNDING, LLC JANICE L SPAHR 33 W LOCUST ST MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: JANICE L SPAHR Account Number: 5121079717195280 Original Creditor: CITIBANK/SEARS Balance Due: $14,140.06 Our File No.: 243976 EXHIBIT "A" Our File No.: 24397b 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. JANICE L SPAHR Defendant. r~F THE F'?`'~''~'':~?A:,,'?TARY 2Qf0 JUfm 30 f~P~ f2~ ~9 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-3526 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys f laintiff A Law Firm Enaa~ Debt Collection By: David J. Apa`t~i~r, Esquire Dated: 6/21 /2010