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Home My WebLink About10-3598 ,1 LVNV FUNDING, LLC 15 SOUTH MAIN STREET STE 500 GREENVILLE, SC 29601 Plaintiff, Our File No.: 244523 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 ,p..?`?1 A?tY L* TVs 20,5 im - r QK a=14 COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. GINO F MORELLI 6 GREEN CIR CAMP HILL, PA 17011-4224 Defendant. NO.. g, 3s?'f 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 C'll WO 70 010 Our File No.: 244523 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 Plaintiff, vs. GINO F MORELLI 6 GREEN CIR CAMP HILL, PA 17011-4224 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 GINO F MORELLI, an adult individual residing at 6 GREEN CIR CAMP HILL, PA 17011-4224. 3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account #6035320490700521; and said account was issued to Defendant(s) by CITIBANK/THD, 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 $2,499.39. 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 $2,499.39 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASWCWES, P.C. Attorney A Law Firm Enaac BY: Dated: 5/25/2010 David J. Aph tthaker, Esquire Our File No.: 244523 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 tS osworn falsification to authorities. David J. Apotha cker, Esquire Attorney for Plaintiff DATE: 5/25/2010 LVNV FUNDING, LLC GINO F MORELLI 6 GREEN CIR CAMP HILL, PA 17011-4224 STATEMENT OF ACCOUNT Debtor's Name: GINO F MORELLI Account Number: 6035320490700521 Original Creditor: CITIBANK/THD Balance Due: $2,499.39 Our File No.: 244523 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ~~`"~~~ nt ~~~~~r}'~'~e Chief Deputy C5 .-~.. '? ~'`-'-: f~~i~6 ~~ -HE S`~,RIFF ~ tr CL~^ '~'4j;rr1flr:Y 20{0 JU~~ _g A~~1 8~ 43 CU~~~w.; ,^~, ~ t. ~FJ~N~Y ~c~~~~~`~'i..V~h~!~! LVNV Funding, LLC ~ vs. Gino F. Morelli Case Number 2010-3598 SHERIFF'S RETURN OF SERVICE 06/04!2010 05:49 PM -Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on June 4 2010 at 1752 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gino F. Morelli, by making known unto himself personally, at 6 Green Circle, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. /.~~Z~G/ STEPHEN BENDER, DEPUTY SHERIFF COST: $41.50 June 07, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (c7 CountySuite 5herifl. Teleosoft. Inc. ~ ti. ... r. ~~r ~~ ~ ~ Our File No.: 244523 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 2010 J~. 27 ~ ~ i2~ 5N CUP~~= .~iv~~~r?`~' F'~ `~''v`i;`L~'r;`~'l: COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. GINO F MORELLI NO. 10-3598 CIVIL Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS,SQCIATES, P.C. A Law Firm Enaa~ed i~I Debt Collection By: David J. Ap thaker, Esquire Dated: 7/13/2010