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HomeMy WebLinkAbout10-4646Y f Our File No.: 265016 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 SUITE 500 GREENVILLE, SC 29601 Plaintiff, vs. LINDA SINGER 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642 Defendant. 1 ,j, ? i r r. + u COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I 0 - y lo4(v 0"I"; l (er t 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 ga.oo PA AT?l e t l8gq ?I Our File No.: 2650.16 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 SUITE 500 GREENVILLE, SC 29601 Plaintiff, VS. LINDA SINGER 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LVNV FUNDING LLC, 15 SOUTH MAIN STREET SUITE 500, GREENVILLE, SC 29601. 2. Defendant(s) is/are LINDA SINGER, an adult individual residing at 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642. 3. Plaintiff, LVNV FUNDING LLC, is the Assignee and Successor in Interest of Account # ending in 3185; and said account was issued to Defendant(s) by HSBC/ORCHARD BANK, 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 $1,507.41. 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 $1,507.41 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & OCIATES, P.C. Attorne for laintiff A Law Firm En 'aged n Debt llectiol BY: Dated: 7/7/2010 David J. Afaker, Esquire Our File No.: 265016 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 relatin to unworn falsification to authorities. i David J. ?fliaker, Esquire Attorny for Plaintiff DATE: 7/7/2010 LVNV FUNDING LLC LINDA SINGER 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642 STATEMENT OF ACCOUNT Debtor's Name: LINDA SINGER Account Number: ending in 3185 Original Creditor: HSBC/ORCHARD BANK Balance Due: $1,507.41 Our File No.: 265016 EXHIBIT "A" I Our File No.: 265016 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING LLC ) Plaintiff ) VS. ) NO LINDA SINGER ) Defendant ) FILED-OFRCE OF THE FRQTHONOTAR 2010 DEC 13 AM 11 -- 59 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 10-4646 CIVIL TERM Civil Action 0z 0 q rn co - rr, --r -?? ?Q <o ©ca PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: _' V r Kindly enter judgment against Defendant, LINDA SINGER, in the default off an" nsv er, in the amount of $676.04 computed as follows: Amount claimed in complaint: $ 1,507.41 Less: Amount Paid: ( 600.00) Plus: Interest from July 7, 2010 to December 2, 2010 at the legal interest rate of 0.00% per annum -231.37 Attorney fees 0.00 TOTAL $ 676.04 I certify that Defendant, LINDA SINGER, last o address is 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642. 1 David J. Apothaker, Esq. Attorney for Plaintiff Dated: December 2, 2010 tLA X14' ?? as ? OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: LINDA SINGER 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642 LVNV FUNDING LLC Plaintiff VS. LINDA SINGER Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY } NO.: 10-4646 CIVIL TERM Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Ayothaker. Esq. at this telephone number: 800-672-0215 fljlm 4.0 `r Our File No.: 265016 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff LVNV FUNDING LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. LINDA SINGER NO.: 10-4646 CIVIL TERM Civil Action Defendant CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: December 2, 2010 David J. Apothaker, Esq. Attorney for Plaintiff Our File No.: 265016 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS OF LVNV FUNDING LLC ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 10-4646 CIVIL TERM LINDA SINGER ) Civil Action Defendant ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 25 GUTSHALL RD SHIPPENSBURG, PA 17257-9642. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the our inquiry indicated that the Defendant(s) is/are i tta Center has sent back David J. Apothaker, Esq. 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UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 34 S. BEDFORD ST. CARLISLE, PA 17013 717-249-3166 Date: August 23, 2010 BAR isl DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423