HomeMy WebLinkAbout10-5384Our File No.: 267950
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.
JULIE HOLDERBAUM
430 W SIMPSON ST
MECHANICSBURG, PA 17055-3762
Defendant.
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY '.o
NO.. 1a P
IC)- J`"JFsy `n
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
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Our File No.: 267950
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.
JULIE HOLDERBAUM
430 W SIMPSON ST
MECHANICSBURG, PA 17055-3762
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 JULIE HOLDERBAUM, an adult individual residing at 430 W SIMPSON
ST MECHANICSBURG, PA 17055-3762.
3. Plaintiff, LVNV FUNDING, LLC, is the Assignee and Successor in Interest of Account # ending
in 1122; and said account was issued to Defendant(s) by CREDIT ONE BANK, NA, 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 $845.59. 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
$845.59 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & AS CIATES, P.C.
Attorney fob aintiff
A Law Firm EngageAlh Debt CAlectioi
BY:
David J. ApT faker, Esquire
Dated: 8/12/2010 \\
Our File No.: 267950
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 relati?@ to unworn falsification to authorities.
David J. A?, Esquire
Attorn for Plaintiff
DATE: 8/12/2010
LVNV FUNDING, LLC
JULIE HOLDERBAUM
430 W SIMPSON ST
MECHANICSBURG, PA 17055-3762
STATEMENT OF ACCOUNT
Debtor's Name: JULIE HOLDERBAUM
Account Number: ending in 1122
Original Creditor: CREDIT ONE BANK, NA
Balance Due: $845.59
Our File No.: 267950
EXHIBIT "A"
267950
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.6390
Fx: 717-240-6397
Plaintiff/s: Court Number:
LVNV FUNDING, LLC Expiration Date:
Type of Action:
Civil Action
Defendant/s:
JULIE HOLDERBAUM
Serve Upon:
JULIE HOLDERBAUM
Address for Service:
430 W SIMPSON ST
MECHANICSBURG, PA 17055-3762
Alternate Address for Service:
Type of Service:
( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting
Special Service Instructions:
* * If service is to be made by deputized service to another county please specify which
county
Filing Attorney Information:
Name: Apothaker & Associates, P.C.
Address: 520 Fellowship Road C306
Mount Laurel, NJ 08054
Telephone: 215-634-8920
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
1tt111? fl1 4,i,+lJfi/7
It
FILED-OFME
OF THIF' - " N IOTAAY
10 CEP-9 AM 8.43
Richard W Stewart
Solicitor
`?fJUNTY
PENNSYLVANIA
LVNV Funding, LLC
vs.
Julia Ann Holderbaum
Case Number
2010-5384
SHERIFF'S RETURN OF SERVICE
09/07/2010 11:10 AM - Jason Vioral, Sergeant, who being duly sworn according to law, states that on September 7,
2010 at 1110 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Julia Ann Holderbaum, by making known unto herself personally, at The Cumberland
County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania
17013 its contents and at the same time handing to her personally the said true and correct copy of the
same.
SHERIFF COST: $37.00
September 07, 2010
JASO 10 L, DEPUTY
S SWERS, f
RON R ANDERSON, SHERIFF
,C7 ca rn"Sulle j}pe sff 'f e!eos;i f. l"C.
Our file No.: 267950
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
LVNV FUNDING, LLC
Plaintiff,
vs.
JULIE HOLDERBAUM
Defendant.
'FILED-OFFICE
OF-,-ME PROTNONOTAR"t
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COURT OF COMMONS PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 10-5384-CIVIL
Civil Action
STIPULATION IN LIEU OF JUDGMENT
The matters and things in controversy having been discussed by and between the parties,
and a settlement having been agreed upon:
It is on January 04, 2011, STIPULATED by and between LVNV FUNDING, LLC
("Plaintiff') and JULIE HOLDERBAUM ("Defendant"), as follows:
1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of
$845.59.
2. Defendant agrees to pay to Plaintiff the sum of $845.59, which sum Plaintiff agrees to
accept in full settlement of its claim herein.
3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum.
4. Defendant shall remit payment(s) in the following manner:
a. $50.00 to be paid on or before January 10, 2011;
b. $50.00 to be paid on or before the l Ot" day of each month, beginning February
10,-2011 until paid in full.
5. All checks shall be made payable to "LVNV FUNDING, LLC", and sent to the office of
Plaintiff s attorney, Apothaker & Associates, P.C., located at the following address:
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
1
a.
6. In the event Defendant fails to pay in accordance with the terms set forth in this
Stipulation and the default is not cured within ten (10) days, then Plaintiff shall be
entitled to obtain the entry of Judgment against Defendant in the suit amount specified in
paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon
ex parte application, with supporting certification, and with notice to Defendant in the
form of a copy of the application addressed to Defendant by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
By: r
Be Weeytto avall aro, Esquire
ID# 307949
Apothaker & Associates, P.C.
Attorneys for Plaintiff
By: k '6
I HOLDERBAUM
Defendant
2
Our File No.: 267950
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D.# 307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
LVNV FUNDING, LLC
Plaintiff
vs.
JULIE HOLDERBAUM
Defendant
D t5 t5 ? "i ?-`,
tl JAN 11 2011 !?
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
1
NO.: 10-5384-CIVIL
Civil Action
ACCEPTANCE OF SERVICE
I accept service of the Complaint in the above referenced matter.
Date:
JU HOLDERBAUM, Defendant
Address.
430 W SIMPSON ST
MECHANICSBURG, PA 17055-3762
Our File No.: 267950
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,
Defendant.
VS.
JULIE HOLDERBAUM
4
2312 JUN 14 P 1
. 1t1OERLAND COU T%
N SYLVANIA.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 10-5384-CIVIL
PRAECIPE TO MARK JUDGMENT SATISFIED
TO THE PROTHONOTARY:
Please mark the Judgment Satisfied against the Defendant. Judgment has been paid
in full.
APOTHAKER & ASSOCIATES, P.C.
Attorneys PI 'ntiff
A Law Firm Enga din ebt Collection
By:
David J. Apothaker, Esquire
R.sopd aN?
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